This paper develops a post-tax asset pricing model under the assumptio
n that investors cannot defer the taxation of capital gains by costles
sly short selling tax exempt perfect substitute securities. Contrary t
o existing literature, it is demonstrated that trading rules of immedi
ate realization of losses and voluntary deferral of gains may not be o
ptimal. Further, equilibrium prices are shown to be higher for stocks
held by investors with large accrued capital gains and lower for stock
s held by investors with small accrued capital gains or losses. (C) 19
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