(B) the value of a partner's ownership interest in such partnership under paragraph (2)(C) shall not be less than the value of the partner's capital account under section 704, and (C) the Secretary shall provide rules for determining the share of a holder of an ownership interest in such an entity of amounts included in an applicable financial statement of such entity for purposes of applying paragraph (2)(D). (7) Secretarial authority The Secretary shall prescribe such regulations, rules, and guidance as may be necessary to carry out the purposes of this subsection, including regulations, rules, and guidance which— (A) prevent the avoidance of such purposes, (B) provide rules for the application of paragraph (2)(C), including in cases of transactions in which gain or loss is not recognized in connection with contributions, distributions, and sales of substantially similar property from which value may be derived, and (C) provide rules for determining the applicable value of assets in taxable years beginning before the date of the enactment of this part. 498. Other definitions