- 4 -
prepared utilizing the cash receipts and disbursements method of
accounting.
On their joint Federal income tax returns for the 1980
taxable year, petitioners claimed ordinary losses from Hunter
transactions for the cancellation of long gold futures contracts
in the amount of $1,530,268, and short-term capital gains for
offset transactions of $198,030. Petitioners also claimed as
miscellaneous itemized deductions for the taxable year ending
December 31, 1980, the following costs relating to their partici-
pation in Hunter transactions: Investment advisory fees in the
amount of $14,000 and legal fees related to investments in the
amount of $3,500.
On their joint Federal income tax return for the 1981
taxable year, petitioners claimed an ordinary loss from Hunter
transactions for the cancellation of long gold futures contracts
in the amount of $55,302 and net long-term capital gains from the
assignment and offset of Hunter gold futures contracts in the
amount of $97,160.
On their joint Federal income tax returns for the 1982
taxable year, petitioners claimed net long-term capital gains
from Hunter transactions for the assignment and offset of gold
futures contracts in the amount of $1,172,950.
All of the above claimed tax results purportedly occurred
with respect to transactions in gold futures conducted during
1980, 1981, and 1982 in the manner hereinafter described on
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