- 13 -
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
liquidation.
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
straddles.
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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