IRS guidance Rev. Rul. 2002-66 Rev. Rul. 2002-66, 2002-2 C.B. 812

2002-10-02 · Internal Revenue Service

A purchased put on the same stock makes a stock plus qualified covered call pair part of a larger straddle, so the section 1092(c)(4)(A) exemption does not apply. In a later-put case the exemption is lost from the date the put is acquired. Cites H. Rep. 432 (1984) and S. Rep. 144 (1981).

Cites § 1092 (c)(4)(A)×7 (c)(4)×6 (a)(2)(B)(iii)×3 (a)×1 (c)×1 (c)(4)(B)×1 (d)(3)×1