RenTech had the same idea and it made the IRS pretty mad: https://www.bloomberg.com/opinion/newsletters/2019-11-13/money-stuff-you-can-t-just-call-loans-options

RenTech had the same idea and it made the IRS pretty mad: https://www.bloomberg.com/opinion/newsletters/2019-11-13/money-stuff-you-can-t-just-call-loans-options https://www.bloomberg.com/opinion/newsletters/2019-11-13/mon... I believe it's still being litigated, so the legality hasn't been firmly established yet.