- 22 - In January 1982 petitioner and Hunter continued to reduce the condor position. This was made necessary by the fact that all the remaining gold contract positions consisted of 1982 contracts and would have to be settled by delivery if held much longer. As a result of the impending delivery dates, petitioner liquidated 30 of the remaining long August positions on Janu- ary 26, 1982. The repositioning resulted in an offset loss of $1,007,100, which petitioner treated as a long-term capital loss. Also on January 26, 1982, an equivalent short position consisting of 30 contracts of February 1982 gold was liquidated, but, instead of being offset by a direct purchase on the trading floor of COMEX, the short position was "assigned". This assign- ment resulted in a profit of $1,149,450, which petitioners reported as a long-term capital gain on their 1982 Federal income tax return. The liquidation continued on February 24, 1982, when 25 long March contracts were sold, and 25 short June contracts were assigned. Petitioner recognized an $802,500 loss from the offset of the March position, which he treated as a long-term capital loss. Simultaneously, petitioner recognized a $1,067,625 profit from the assigned short June position, which petitioner treated as a long-term capital gain. On February 25, 1982, an additional 25 contracts on each side of the remaining spread position in the account were liquidated. Twenty-five long March 1982 contracts were offset atPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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