Field Service Advice, CC:TL-N-10593-92. In-the-money covered calls written before the 1984 amendments: whether deep-in-the-money calls reduce the 246(c) holding period. A call with virtual economic certainty of exercise is a contractual obligation to sell; depth is primarily a question of fact, judged on strike gap and volatility, with 1092(c)(4)(C) as a guideline. Defers to the field on the facts. Redacted; not precedent.