# FSA 0956 (FSA 1992-1130-4): FSA 0956 (FSA 1992-1130-4), Field Service Advice, Nov. 30, 1992

IRS guidance. 1992-11-30 · Internal Revenue Service.

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.

Cites 26 U.S.C. § 1092: § 1092(c)(4) (2x), § 1092(c)(4)(C) (2x)