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I have a number of "straddle" situations, sometimes with several different positions, where one side is larger than the other. When the straddle rules were implemented it was anticipated that regulations clarifying how to deal with such situations would be written however, after many hours of research, I can safely say they have not been published.

Without the regulations I have no way of determining which parts of which positions to include in the straddle. In a weak momement I even called the IRS to ask. (They are not allowed to answer questions about straddles.) I even went to a law libarary and spent several hours looking through tax court rulings to try to find some precident, to no avail. (I guess I should not have expected the court to do the IRS' work for them.) I also was unable to find any temporary regulations which helped.

Can anyone offer any suggestions on how to handle this.

Many thanks,
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