duff and bill...just a little input from moi. i would think the only way it would become an issue would be if audited and the IRS agent REALLY wanted to push the issue. it's clearly a "grey" area for the IRS, but i doubt, once all the facts are assessed, the IRS would push it. clearly, there are two different companies in MRVC and LMNE. I think you'd be much better off in the instance where you were selling MRVC and buying LMNE, than vice versa. only b/c MRVC DOES own 90+% of LMNE. doing the opposite, you're giving up the remaining valuation of OPXS, CWNT, Zaffire, etc. i mean, to me, selling LMNE and buying NUFO would be closer to a problem, and that's NEVER been taken into the scope of the meaning of the IRS wash rules. at least LMNE and NUFO have almost identical businesses....
i really think the intent of the rule is more for purchasing a different type of security (ie, options) in the same company.
but, hey, i'm not a cpa, and i don't play one on tv. if the irs wants to look at the issue, i know a few people i can hand over to them! <VBG> |
