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To: DaveMG who wrote (61408)	1/11/2000 9:29:00 AM
From: LLCF	Respond to of 152472

<It's a "if it looks like a duck" rule - if you've done something to eliminate all your risk, then you've performed the moral equivalent of selling your stock, and should be taxed the same as someone who did.> Yes, but unfortunately in real life there are a lot of breeds/types/ages/etc. of Ducks and their relatives. If the tax code was more simplified and straight forward [flat tax] rather than these artificial levels and timelines it would eliminate an entire army of accountants and lawyers. Bring back Jerry Brown! I can just see a conversation now: Investor: But when I sold the calls they were only 49 delta. IRS: Wait a second, what volatility were you using, we believe they were a 51 delta constituting a de-facto sale of your stock! Investor: But Look over here at that guy, he bought in the money puts and protected his entire portfolio! IRS: Actually, we haven't learned puts yet, there aren't many people here less than 6 years that do, so we don't look at those unless they are on the same strike as a call, then we bring in someone senior. Investor: But I SOLD puts. IRS: Oh, can you do that? Investor: Ughhhhh. Next time I'll just do a swap. IRS: What's that. DAK