fb-wash-0007
{
"facts": "On March 10, 2026, a taxable account sells 200 shares of PQR common stock at a loss. On April 8, 2026 — 29 days after the sale — it buys 200 shares of the same PQR common stock. There are no other PQR transactions in 2026. The taxpayer is not a dealer.",
"sale_date": "2026-03-10",
"repurchase_date": "2026-04-08",
"shares_sold": 200,
"replacement_shares": 200
}How does section 1091 treat the realized loss on the March 10 sale? Answer with exactly one option id.
loss-disallowed-fully— The loss is disallowed in fullloss-disallowed-partially— The loss is disallowed in partloss-fully-deductible— The loss is fully deductibleno-loss-nothing-to-disallow— There is no loss, so section 1091 does not apply
loss-disallowed-fully
The statutory window runs 30 days before through 30 days after the March 10 sale, so it closes at the end of April 9, 2026. The April 8 repurchase falls 29 days after the sale, inside the window, and the 200 replacement shares match all 200 sold shares. Under section 1091(a), no deduction is allowed for the loss.
Selects loss-disallowed-fully; the repurchase is inside the 61-day window and fully matched.
“within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired (by purchase or by an exchange on which the entire amount of gain or loss was recognized by law), or has entered into a contract or option so to acquire, substantially identical stock or securities, then no deduction shall be allowed”
Each quoted passage is exact-matched, after typographic normalization, against the corpus text fetched from the issuing authority (hashes in the corpus manifest). An item whose quote stops matching fails the build.
“within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired” — usc-1091
The key is correct. Initial logic and parameters are validated. The April 8 repurchase occurs 29 days after the March 10 sale, falling within the statutory 30-day window, resulting in full disallowance of the loss.
“within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired (by purchase or by an exchange on which the entire amount of gain or loss was recognized by law), or has entered into a contract or option so to acquire, substantially identical stock or securities, then no deduction shall be allowed” — usc-1091
April 8, 2026, is 29 days after March 10, 2026, so the reacquisition is within the 30-day statutory window. The replacement is 200 shares of the same PQR common stock, matching all 200 shares sold, so the realized loss is disallowed in full under §1091(a). The taxpayer is not a dealer, so no dealer exception applies.
v1; no errata. Demonstrate a key error and the correction is published here, credited — challenge policy.