Robert G. Leslie and Marilyn B. Leslie - Page 13

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                    are possible.  You should select the one that ful-                
                    fills your economic goals and personal require-                   
                    ments.  Get the advice of your tax adviser.                       
               Included with the promotional material are four graphs which           
          show pre- and post-tax analyses of contract liquidation.  The               
          promotional material also contained a "Worksheet" which specifi-            
          cally allows for calculating the "Tax Savings" of contract                  
               Also provided with the Hunter promotional material was a               
          four-page document entitled "Summary of Federal Income Tax                  
          Consequences of F.G. Hunter & Associates Investment Program",               
          giving a synopsis of the different tax implications of various              
          gold futures contract liquidation methods.                                  
               The Hunter promotional materials included a 24-page opinion            
          letter, dated March 24, 1980, written by Attorney Avram Salkin.             
          The opinion letter was supplemented on June 13, 1980, and                   
          modified on August 17, 1981, in light of the provisions of the              
          Economic Recovery Tax Act of 1981, Pub. L. 97-34, 95 Stat. 172.             
          The opinion letter described in detail, with supporting citations           
          of case law and statutes, the tax consequences, which in, the               
          opinion of Mr. Salkin, could be expected by Hunter investors from           
          the liquidation of the component positions of their future                  
          Petitioner's Business and Investment History                                
               At the time of trial, petitioner was 62 years old.  Peti-              
          tioner graduated from high school in 1950 and enlisted in the               

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