Such positions generally are referred to in the financial markets as straddles
. A foreign currency arbitrage trading strategy may employ several major currencies, including currencies of the industrialized nations for which there are regulated futures contracts, as well as the currencies of smaller nations.
Based on prior case law, the Tax Court found clear authority that there was no common law wash sale doctrine with respect to a continuous position in a commodity future; the question was whether a common law doctrine existed with respect to straddles
. The court noted that prior case law supported a non-statutory wash sale doctrine where a party had not completely relinquished an economic investment in the same, or substantially identical, investment.
Regulations use the term "identified mixed straddle
" to refer to those straddles
for which the taxpayer has elected "straddle-by-straddle identification." To avoid confusion, this discussion will refer to straddles
for which this election has been made as "mixed straddles
." In order to make a straddle-by-straddle identification election, the taxpayer must clearly identify each position that is part of the mixed straddle
before the close (i.e., midnight, local time) of the day on which the straddle
Rajesh purchases 6,450 RST Index options and enters the long straddle
; Naveen sells 6,550 RST Index options and enters short straddle
These 5--and 6-letter straddles
are names: CORNEAL LENS (Cham), TOTAL THEATRE, RADIANT HEAT, ARABIAN CAMEL, GOLDEN CHAIN (Dench is a surname), BODY LANGUAGE, FORTIFIED WINE, MIDDLE NAME, HUMAN DYNAMO, PUERPURAL FEVER
In trading straddles
on a market index such as the S&P 500, it is important to have a good understanding of the dynamics of volatility through time.
The behavioral interactions involved one or both lizards exhibiting at least one of the following seven behaviors: supplant, trail, straddle
, chase, face-off, arched back display or straddle-bite (Table 1).
The IRS concluded in FSA 1999-664 that "substantial litigation hazards" existed with disallowing the taxpayer's prestraddle loss, and that the regulations did not preclude the taxpayer from establishing identified mixed straddles
with only those positions that would produce a capital loss.
PROPERTY SUBJECT TO STRADDLE
RULES Section 1256 Contracts Non-Section 1256 Property Regulated futures contracts Stock options Nonequity option contracts (see Q 1068) Other equity options (see Q 1067) Foreign currency contracts Direct ownership of stock--but only when Dealer equity options at least one offsetting position is: 1) an option (other than a qualified covered call option) on such stock or on substantially similar stock or securities; 2) substantially similar property; or 3) stock of certain corporations which take positions that offset positions held by Shareholders (see Q 1078) Forward contracts Other actively traded personal property which is not a Section 1256 contract Securities futures contracts (see Q 1072) 1078.
"When the corps is together," she says, "the ballets look incredible." Although she often straddles
the line between ranks (she had featured roles in Ashton's The Dream and Paul Taylor's Black Tuesday), Butler likes to talk about the Act II ensemble work in Giselle or the Shades adagio from La Bayadere--scenes that, for her, make dancing an almost surreal experience.
Narrator Canada gives a great performance that straddles
an ethnic mix of characters.
Today, what's left of the Chicxulub crater, which is named for the fishing village near its center, straddles
the northwest coast of Mexico's Yucatan peninsula.
Vidal delights partly because he so insolently straddles
the line between high art and dish.
On the approaches to St Petersburg, it straddles
a cluster of islands with an intricately woven network of daunting rubble bastions, curtain walls and ravelins punctuated by austere ashlar NeoClassical openings.