Theodore A. Andros and Joan B. Andros - Page 50

                                        -50-                                          
              This strategy reduced Tandrill’s overall potential for economic         
         profit or loss, but substantially increased its transactional costs.         
         We are convinced that Tandrill’s primary aim was to generate tax             
         benefits.                                                                    
              The tax-motivated nature of Tandrill’s futures straddles is             
         reflected in the timing of the transactions that closed out its              
         losses.  For example, in 1979 the loss legs of the precious metals           
         straddles were closed out on dates of large price movements in the           
         underlying metals.41  The record indicates that in November 1979,            
         traders closed out their short silver positions and simultaneously           
         replaced them with other short silver positions.  The sole                   
         motivation of this strategy was to lock in a tax loss for 1979 and           
         to push the corresponding gain into 1980.  This is precisely what            
         Tandrill did.  Of the 721 silver contracts that it closed out in             
         1979, 718 were closed out either on November 21, 1979, or November           
         27, 1979, landmark dates for large price movements.                          


              40(...continued)                                                        
          futures straddles cleared through ACLI.                                     
               41   For instance, in November 1979, the price of silver               
          futures fluctuated far more than normal. This meant that for                
          traders holding silver spreads, both long and short legs                    
          increased sharply in value, placing the long leg in a position              
          with a substantial profit and the short leg in a position with a            
          substantial loss.  For tax-motivated individuals,  this was the             
          optimal occasion to close out the loss leg, realizing the loss              
          for tax purposes, and to replace that position with another short           
          position comprising the same number of silver contracts                     
          (typically with a delivery date late in 1980).                              






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