Notice 2015-73, Listing Notice – Bas-

ket Option Contracts, 2015-46 IRB 660 (11-16-2015). Notice 2015-73 identifies as a listed transaction a type of structured financial transaction in which a taxpayer attempts to defer and treat ordinary income and short-term capital gain (earned under a contract denominated as an option contract that references a basket of securities) as long-term capital gain. The IRS will no longer defend this listed transaction notice in accordance with Action on Decision 2024-1, 2024-52 IRB 1354 (12-24-2024). .02 The following notice applied to the Troubled Asset Relief Program, which is no longer operative: