fb-wash-0011
{
"facts": "On June 2, 2026, a taxable account sells 200 shares of YZA at a loss. On June 18, 2026 it buys 80 shares of YZA. There are no other YZA acquisitions within 30 days before or after the sale. The taxpayer is not a dealer.",
"sale_date": "2026-06-02",
"repurchase_date": "2026-06-18",
"shares_sold": 200,
"replacement_shares": 80
}How does section 1091 treat the realized loss on the June 2 sale? Answer with exactly one option id.
loss-disallowed-fully— The loss is disallowed in fullloss-disallowed-partially— The loss is disallowed in part — only the matched sharesloss-fully-deductible— The loss is fully deductibleno-loss-nothing-to-disallow— There is no loss, so section 1091 does not apply
loss-disallowed-partially
The June 18 repurchase is 16 days after the sale, inside the window, but only 80 replacement shares were acquired against 200 sold. Under section 1091(b) and the matching rule of 26 CFR 1.1091-1(c), only the loss on the 80 matched shares is disallowed; the loss on the remaining 120 shares stays deductible.
Selects loss-disallowed-partially; 80 of 200 shares are matched.
“If the amount of stock or securities acquired (or covered by the contract or option to acquire) is less than the amount of stock or securities sold or otherwise disposed of, then the particular shares of stock or securities the loss from the sale or other disposition of which is not deductible shall be determined under regulations prescribed by the Secretary”
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.
“If the amount of stock or securities acquired (or covered by the contract or option to acquire) is less than the amount of stock or securities sold or otherwise disposed of, then the particular shares of stock or securities the loss from the sale or other disposition of which is not deductible shall be determined under regulations prescribed by the Secretary.” — usc-1091
The key correctly identifies that the loss is disallowed partially. The June 18 repurchase is within the 30-day window, but only 80 replacement shares were acquired against 200 sold. Under section 1091(b), only the loss on the 80 matched shares is disallowed; the loss on the remaining 120 shares stays deductible.
“If the amount of stock or securities acquired (or covered by the contract or option to acquire) is less than the amount of stock or securities sold or otherwise disposed of, then the particular shares of stock or securities the loss from the sale or other disposition of which is not deductible shall be determined under regulations prescribed by the Secretary.” — usc-1091
The June 18 purchase of 80 YZA shares is within 30 days after the June 2 sale, so section 1091 applies. Because the amount acquired (80) is less than the amount sold (200), subsection (b) provides that only the particular shares matched under regulations have their loss disallowed, rather than the full loss. Thus the key's partial-disallowance answer is correct; the remaining 120 shares' loss is not disallowed.
v1; no errata. Demonstrate a key error and the correction is published here, credited — challenge policy.