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In other words, is there a good reason why a zero difference between redemption and purchase price cannot be considered a loss?

See the Pub 550 discussion, paying special attention to the discussion of gains and losses on the same day.

Phil Marti

I looked at the “loss and gain on same day” section with the example on page 52 of http://ftp.fedworld.gov/pub/irs-pdf/p550.pdf, but I don't see how it is relevant at all to my question. It still doesn't clarify whether zero should be considered a loss or whether zero should be considered a gain.

Let me try to present the example scenario slightly differently, noting how I have split the share redemption step into two separate steps:

(1) 100 shares purchased on 06/01/2001 at \$40/share

(2) 100 shares purchased on 07/02/2001 at \$50/share

(3) 100 shares purchased on 08/01/2001 at \$30/share

(4) 100 shares from 06/01/2001 redeemed on 08/08/2001 at \$40/share

(5) 100 shares from 07/02/2001 redeemed on 08/09/2001 at \$40/share

Would/could step #4 be considered a wash sale or not?

If so, then the shares purchased in step #3 would have its effective purchase date changed from 08/01/2001 to 06/01/2001, and their cost basis of \$30/share would be adjusted by \$0/share to \$30/share. Hence, the only shares still held are 100 shares purchased on 06/01/2001 and 100 shares purchased on 07/02/2001. Then, step #5 would not be a wash sale, where a loss of \$10/share would be recognized.

If not, then the only shares still held after step #4 are 100 shares purchased on 07/02/2001 and 100 shares purchased on 08/01/2001. Next, step #5 would result in a wash sale, where there would be a disallowed \$10/share loss on the shares purchased on 07/02/2001. The replacement shares bought on 08/01/2001 would have their effective purchase date changed to 07/02/2001, and their original cost basis of \$30/share would be increased by \$10/share to \$40/share.

Now if steps #4 and #5, respectively, became

(4) 100 shares from 06/01/2001 redeemed on 08/08/2001 morning at \$40/share

(5) 100 shares from 07/02/2001 redeemed on 08/08/2001 afternoon at \$40/share

then I don't see any reason for a difference in the tax results. This situation is also basically the same as the example in my very first post in this thread, besides for the established ordering of when the share lots (between the lot purchased on 06/01/2001 and the lot purchased on 07/02/2001) were sold.

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