wealthschema / benchmark / items / fb-wash-0016
ITEM PROVENANCE · WASH-SALE-MECHANICS

fb-wash-0016

status: publishedversion: v1corpus: 2026.9key: derivedseverity: high
Scenario (all facts stipulated)
{
  "facts": "On July 1, 2026, a taxable account sells 150 shares of HIJ common stock at a loss. On July 31, 2026 — exactly 30 days after the sale — it buys 150 shares of the same HIJ common stock. There are no other HIJ transactions within the window. The taxpayer is not a dealer.",
  "sale_date": "2026-07-01",
  "repurchase_date": "2026-07-31",
  "shares_sold": 150,
  "replacement_shares": 150
}
Question posed to the model under test

How does section 1091 treat the realized loss on the July 1 sale? Answer with exactly one option id.

Answer options
  • loss-disallowed-fullyThe loss is disallowed in full — day 30 is inside the window
  • loss-disallowed-partiallyThe loss is disallowed in part
  • loss-fully-deductibleThe loss is fully deductible — the window closed before the repurchase
  • no-loss-nothing-to-disallowThere is no loss, so section 1091 does not apply
Answer key

loss-disallowed-fully

Derivation from the cited text

The statutory period ends 30 days after the sale date. July 31, 2026 is exactly 30 days after July 1, 2026, so the repurchase falls on the final day of the period — inside it, not past it — and the 150 replacement shares match all 150 sold shares. Under section 1091(a) the loss is disallowed in full. Treating day 30 as already outside the window is the tested error.

Rubric

Selects loss-disallowed-fully; day 30 is the last day inside the window.

Cited primary sources (quote-gated)
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.

Verification record
generator: claude-fable (session 2026-09-01)disagreements: 0controls: fb-2026-09-c (3/3 caught)adjudicated by: — (none required or pending)
gemini-3.1-pro-previewagrees the key is correctquote matched
within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such dateusc-1091

The key is correct. Initial logic and parameters are validated. July 31 is exactly 30 days after July 1, falling within the statutory window, so the loss is disallowed in full.

deepseek-v4-proagrees the key is correctquote matched
within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such dateusc-1091

July 31, 2026 is exactly 30 days after July 1, 2026, so the repurchase occurs on the ending date of the statutory 30-day period. The quoted text includes that date within the window. Because the taxpayer repurchased 150 shares of the same stock on that final day and is not a dealer, the full loss is disallowed under §1091(a).

Version history & errata

v1; no errata. Demonstrate a key error and the correction is published here, credited — challenge policy.