Can anyone venture an opinion? I cant see the error in this, but...

Can anyone venture an opinion? I cant see the error in this, but since I haven't sold purely for tax loss considerations before, I'd better ask around.

Because of selling of long held bank shares and whatnot, my family portfolio is due for yet another capital gains tax whack in fy 2009

My earliest purchases of INL were for what is now the stratospheric price of:

100,000 @ 19c, and 100,000 @ 16c = 200,000 shares

The current offer for INL is 1.8c, but let's round off and say I purchase 200,000 tomorrow @ 2c, and immediately (solely for CGT loss purposes), sell the 200,000 for the same price of 2c (for convenient calculation here)

So my total cost would be just the brokerage of approx $60

My holding is exactly the same.

But when I come to calculate my CGT I take either the earliest shares, or those that I bought at the highest price, as the cost basis for the just sold 200,000 shares. (In this case that is conveniently the same parcel of shares)

So the claimable loss on the earliest shares would be 17c per share on the first parcel bought at 19c, and 14c per share on the second parcel at 16c.

Multiply by 100,000 shares for each parcel and that allows me to claim a total capital tax loss of $31,000, before including brokerage costs. All just for the cost of brokerage of buying and selling 200,000 shares. My holding remains the same.

So even though I immediately sold the 200,000 shares that I bought today, I can effectively claim that the 200,000 shares that I sold were the ones I bought over a year ago, and claim a massive tax loss. Essentially what I would be doing is artificially bringing a capital loss forward into a year that would be of benefit to me.
Comprende? Do you think my reasoning is right, and is it legitimate tax accounting?