Theodore A. Andros and Joan B. Andros - Page 34

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          involved futures contracts in copper, gold, 90-day Treasury bills,          
          sugar, GNMA’s, and 30-year U.S. Treasury bonds.27                           
               Mr. Maduff focused on the GNMA’s and bond trades.  He opined           
          that the GNMA and bond28 trades appear to have been intended to roll        
          gains from 1980 into 1981, and in fact succeeded in rolling                 
          $695,156.25 of gains into 1981.  In addition, because these trades          
          involved contracts not maturing until 1982, they had the potential          
          of generating long-term gains and short-term losses.  After                 
          examining these transactions, Mr. Maduff concluded that these               
          trades did not have any profit motive or potential.                         
               The GNMA and Treasury bond transactions were established on            
          June 26 and 27, 1980, with the purchase on each day of: 15 March            

               27   With the exception of the GNMA’s and bonds, all of the            
          transactions were initiated by July 1, 1980, and closed out by              
          Dec. 31, 1980.  Thus, Mr. Maduff did not perform a detailed study           
          of the copper, gold, 90-day Treasury bill, or sugar  transactions           
          because it was clear that they were not used to postpone income             
          recognition from one year to the next.  Also, they did not have             
          the potential for long-term capital gains because all were closed           
          out in less than 6 months.                                                  
               28   Treasury bond futures contracts and GNMA futures                  
          contracts are similar instruments.  Both consist of 30-year debt            
          instruments with a $100,000 face value and a nominal 8-percent              
          “coupon”.  Bonds are obligations of the U.S. Government; GNMA’s             
          are mortgage-backed debt instruments guaranteed by an agency of             
          the U.S. Government.  The primary difference is that, in periods            
          of falling interest rates, GNMA’s are subject to prepayment while           
          bonds are not.                                                              
                    In addition, these debt instruments, which on their               
          face provide a constant income flow for approximately 30 years,             
          will fluctuate in value with interest rates.  However, a 3-month            
          spread in either bonds or GNMA’s will tend to be stable because             
          that spread represents only the difference between 90-day                   
          interest rates and 30-year interest rates for a 90-day period               
          rather than 30-year interest rates themselves.                              




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