The stated facts in the 2003-7 Ruling. . . do not have any implication for future ยง1259 safe harbor collar guidance, [Viva Hammer, an attorney-adviser at the Treasury Department’s office of tax policy] had noted in discussions earlier in the day [at a Jan. 24, 2003 meeting of the A.B.A. Tax Section]. Read Viva’s comments here 2003-2-3 Variable Forward ABA