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To: Labrador who wrote (76345)	7/12/2000 11:28:50 AM
From: edamo	Respond to of 152472

labrador....ot ot "wash rules" it is a very gray area, subject to challenge by the irs and taxpayer. "in-the money" "objective factors..........no substantial likelihood that the put would not be exercised" "in substance a contract to acquire stock" i can see this if the intent is to acquire the stock with a deep in the money option....this appears to be the exception not the rule.... and if applicable can it be challenged should the option expire worthless....????? or is the premium added to the common sale price for a new cost basis????? that's why tax courts exist.....would be curious if any determination letters/rulings have been issued, instead of a hypothetical....