- 4 - 1988 (Kenilworth's 1987 taxable year).1 Kenilworth had $1,000 of capital stock outstanding at the beginning and end of its 1987 taxable year. During all years relevant herein, petitioner and Kenilworth invested primarily in Limited Price Options (LPO's) sold by Bear, Stearns & Co., Inc. (Bear Stearns), and Prudential Bache & Co. (Prudential Bache). An LPO is an extremely high risk, sophisticated financial instrument designed for aggressive hedge funds, risk arbitageurs, and professional traders. In general, a purchaser of an LPO pays 20 percent of the market value of a package of securities in return for the right to buy those securities at a set price during a set period of time. Once purchased, an LPO may be traded only with the brokerage firm from which it was purchased. An LPO is like a conventional option in that it creates leverage to enhance the purchaser's potential gain in a strong market. However, the premium paid for an LPO is generally lower than the premium paid for a comparable conventional option because the terms of the LPO provide that it will automatically expire without value whenever the market value of the related securities falls below a set dollar amount (Expiration Price). To minimize the risk of loss in a declining market, a purchaser of an LPO may execute an addendum to an LPO 1 Kenilworth acquired more than 50 percent of the stock of this subsidiary during Kenilworth's 1987 taxable year. Unless otherwise indicated, our references to Kenilworth are without regard to its subsidiary.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011