effect varies inversely with the probability that the case
In West, the court held that the whipsaw
calculation claim "arises when participants opt to 'cash out' their hypothetical accounts before they reach normal retirement age.
Hence, a taxpayer in this situation faces an interest-rate whipsaw
that another taxpayer may avoid.
If the whipsaw
is applied against taxpayers, the results will be catastrophic.
case is one in which the IRS is confronted by conflicting claims by different taxpayers, often divorcing spouses, concerning the same transaction.
Cable sees intraday whipsaw
trade but ends constructive.
When power prices might whipsaw
, derivatives can help.
CROSS COUNTRY: MIDDAY SNAPSHOT & ANALYSIS OF SELECTED CROSS RATES A very choppy final session of trade for the month thus far, with the whipsaw
price action hurting short-term spec accounts on both sides.
Exactly why same-day description of the hedged item is necessary is not entirely apparent, because identification of the hedging transaction alone should prevent taxpayers from using hindsight to recharacterize gains as capital to whipsaw
According to the Preamble, the IRS chose the "disposition approach" over the "lock-in approach"(9) for a number of reasons including: (1) to eliminate the practical need for costly E&P studies to determine stock basis; (2) to eliminate the need for transitional rules to address whipsaw
and planning opportunities arising from duplication or omission of items under duplicate systems; (3) to eliminate the need to maintain both systems for an indefinite time, and thereby avoiding significant compliance and guidance burdens for both the taxpayers and the government; and (4) to give force to section 1503(e)(1)(A), which requires modifications to stock basis-- retroactive to 1972--that are similar to modifications under the proposed rules.