Robert G. Leslie and Marilyn B. Leslie - Page 22

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               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 at           

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