My understanding is that one of the requirements necessary for a call to be a qualified covered call is that it not be part of a larger straddle. Rev. Rul. 2002-66 has concluded that a stock, long put and short call (a collar) are all one straddle, and the call should not be treated as a qualified covered call. What about a qualified covered call and an additional short OTM call? (long stock short 2 OTM calls, one "naked") Would this position be a tax straddle? How about a constructive sale?