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| | Internal Revenue Bulletin - February 23, 2004 - Rev. Rul. 2004-15 |
 | | Under § 1001(d)(2) of the Taxpayer Relief Act of 1997 (the transition rule), if “before June 9, 1997, the taxpayer entered into any transaction which is a constructive sale of any appreciated financial position, and. |
 | | Thus, the XYZ stock and the Short Sale fall within the transition rule, and, until either TP ceases to hold the XYZ stock or the Short Sale is closed, neither the XYZ stock nor the Short Sale is taken into account in determining whether any constructive sale has occurred after June 8, 1997. |
 | | Accordingly, the transition rule continues to apply to the Short Sale and the XYZ stock. |
| www.irs.gov /irb/2004-08_IRB/ar10.html (1029 words) |
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