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in isolation would allow the investor to profit or lose based on
the relative fluctuation of long and short-term interest rates, the
two positions taken together would result in virtually no
fluctuation at all.
Mr. Maduff’s Conclusions
1. Taken in isolation, Tandrill’s 1979 Treasury bill trading
established through Bache appears to have been taken with a profit
motive.30
2. Tandrill’s 1979 gold, silver, and copper straddle
transactions established through Bache were “tax straddles”,
entered into without an objective of earning an economic profit.
3. Tandrill’s 1980 GNMA and Treasury bond transactions
established through ACLI were “tax straddles”, entered into without
an objective of earning an economic profit.
Mr. Borst
Petitioners’ expert, Thomas J. Borst, received a B.S. in
business administration from Miami University (in Oxford, Ohio) in
1962, and an M.B.A. from the Wharton School of Commerce and Finance
at the University of Pennsylvania in 1964. After working for Inland
Steel Company and International Business Machines Corp., Mr. Borst
became an institutional and retail securities broker with several
securities firms between 1968 and 1974. Later, he began trading on
the Chicago Board Options Exchange as an independent market maker
30 Mr. Maduff asserted that he cannot “be certain” of this
conclusion because of “inadequate documentation”.
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