The Tax Court (Judge Haines) holds that under Sec. 1256 a foreign currency call option is not a foreign currency contract and the marked-to-market provisions of Sec. 1256 do not apply to allow a loss on assignment of the option to a charity.
The Tax Court (Judge Haines) holds that under Sec. 1256 a foreign currency call option is not a foreign currency contract and the marked-to-market provisions of Sec. 1256 do not apply to allow a loss on assignment of the option to a charity.