How are transactions described in Notice 2003-81 resolved under Section 4.A of Announcement 2005-80?
A.1 For purposes of settlement, taxpayers must concede the aggregate loss claimed on their return. In the typical case, the Service will disallow the gains and losses from all the foreign currency contracts reported on either Schedule D or Form 4797. This approach results in the full disallowance of the purported tax benefits claimed.
