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The petitioner, Michael Napoliello, entered into two pairs of offsetting long and short foreign currency option contracts held by an LLC of which he was the sole member.
dollar receivables or payables is a type of transaction risk which can be hedged using forward foreign exchange or foreign currency option contracts. A forward contract is a mutually binding agreement between two parties to exchange a certain amount of one currency for a specific amount of another currency at a date or range of dates in the future.
* Notice 2003-81 offsetting foreign currency option contracts: A party claims a loss on the assignment of a Sec.

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