1.1092(b)-5T—Definitions (temporary).
The following definitions apply for purposes of §§ 1.1092(b)-1T through 1.1092(b)-4T.
(a) Disposing, disposes, or disposed.
The term disposing, disposes, or disposed includes the sale, exchange, cancellation, lapse, expiration, or other termination of a right or obligation with respect to personal property (as defined in section 1092(d)(1) ).
(b) Hedging transaction.
The term hedging transaction means a hedging transaction as defined in section 1256(e).
(c) Identified straddle.
The term identified straddle means an identified straddle as defined in section 1092(a)(2)(B).
(d) Loss.
The term loss means a loss otherwise allowable under section 165(a) (without regard to the limitation contained in section 165(f)) and includes a write-down in inventory.
(g) Offsetting position.
The term offsetting position means an offsetting position as defined in section 1092(c)(2).
(j) Related person or flowthrough entity.
The term related person or flowthrough entity means a related person or flowthrough entity as defined in sections 1092(d)(4) (B) and (C) respectively.
(k) contract.
The term section 1256 contract means a section 1256 contract as defined in section 1256(b).
(n) Successor position.
The term successor position means a position (“P”) that is or was at any time offsetting to a second position if—
(2)
P is entered into during a period commencing 30 days prior to, and ending 30 days after, the disposition of the loss position referred to in paragraph (n)(1) of this section.
(o) Unrecognized gain.
The term unrecognized gain means unrecognized gain as defined in section 1092(a)(3)(A).
(p) Substantially identical.
The term substantially identical has the same meaning as substantially identical in section 1091(a).