This 'Tax alert' seems to make no sense to me. Especially the example where it says that Kelly will be offsetting her $62k loss with her $62k loss - How is this a benefit? Doesn't that simply make her even?
That's even without considering that she had to pay a total of $2000 in brokerage and when she bought the shares back they were 1c higher!
As far as I can tell that is a lose lose lose istuation and then it says "...the Commissioner may make a determination under section 177F to cancel the tax benefit"