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To: The Reaper who wrote (49214)	11/11/1999 5:49:00 PM
From: Voltaire	Read Replies (1) \| Respond to of 152472

Hi kkirby, When I see a post like this, I think of one guy, one the sharpest I have met on any thread. His name is Mark Peterson CPA and author. As far as I know he came over to the thread a few days back and the thread will be a much more informed place because of it. Welcome Mark, Voltaire

To: The Reaper who wrote (49214)	11/11/1999 6:04:00 PM
From: Jon Koplik	Respond to of 152472

No it does not. I am 99.99% positive. Jon. eom.

To: The Reaper who wrote (49214)	11/11/1999 7:13:00 PM
From: RoseCampion	Read Replies (1) \| Respond to of 152472

If someone was to sell some Jan. calls at a much higher strike price to protect some of the profits, thus creating a spread without incurring a tax liability for this year, would the option positions have to be marked to market on Dec. 31 for income tax reasons. I've asked this question on the tax threads, and in several other forums, many, many times. I've not yet gotten a definitive answer. The Section 550 rules are insanely complex. Right now I'm working under the assumption that since you don't have to mark to market a spread that you initially started as a spread, you also don't have to realize the gains on a spread that you later made into a spread due to your followup action of selling the calls. In other words, selling the calls does not constitute a "constructive sale" in the same way that selling a deep-in-the-money covered call on the stock itself does. As long as you don't try to close both halves in different years (eg, take the loss on one half in 1999, defer the gain until 2000) I believe you are within the letter of the law in recognizing the total gain in 2000. But what do I know? If someone gets a definitive answer, do let us all in on it. (I probably need to go back and read the tax chapter in McMillian tonight. Lots of fun.) -Rose- PS: kk - I'm in the same position, and if we open up tomorrow AM, I am SERIOUSLY considering doing the same thing. I've run some analysis on selling 340s or 350s and so far I like what I see. Your mileage may vary.