§98

435 (1992). Section 1253(b)(1) tells us that there's a "franchise" for the purposes ofsection 1253 ifthere is: - 13 - [*13] (cid:16)042an agreement (cid:16)042in which one party receives the right to provide services (cid:16)042within a defined area. See Tele-Commc'ns, 95 T.C. at 509. Ifa transaction satisfies these three requirements, t

435 (1992). Section 1253(b)(1) tells us that there's a "franchise" for the purposes ofsection 1253 ifthere is: - 13 - [*13] (cid:16)042an agreement (cid:16)042in which one party receives the right to provide services (cid:16)042within a defined area. See Tele-Commc'ns, 95 T.C. at 509. Ifa transaction satisfies these three requirements, t

435 (1992). Section 1253(b)(1) tells us that there's a "franchise" for the purposes ofsection 1253 ifthere is: - 13 - [*13] (cid:16)042an agreement (cid:16)042in which one party receives the right to provide services (cid:16)042within a defined area. See Tele-Commc'ns, 95 T.C. at 509. Ifa transaction satisfies these three requirements, t

Exchange gain or loss with respect to a contract described in § 1 .988-2(d)(1) [i .e ., foreign currency forward contracts, futures contracts, and options] shall be determined by subtracting the amount paid (or deemed paid), if any, for or with respect to the contract (including any amount paid upon termination of the contract) from the amount received (or deemed received), if any, for or with respect to the contract (including any amount received upon termination of the contract) . Any .gain or