I.C. Hemmings and Sue B. Hemmings, et al. - Page 7

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          Management Investment Co.  Mr. Hemmings did not understand how              
          the trading programs worked.                                                
               The starting point of these transactions was determining the           
          amount of losses that needed to be generated in order to                    
          substantially reduce or eliminate the Hemmingses' taxable income.           
          Mr. Harris supplied these figures to ACLI and/or ELMS.  Mr.                 
          Hemmings was told that he would not make a profit from these                
          transactions, and that, in return for the fees paid, losses would           
          be produced to defer taxes, followed by the realization of                  
          capital gains in future years in amounts commensurate with the              
          losses.  The purpose of the transactions was to shelter income.             
          Unlike other commodities or financial instrument transactions,              
          Mr. Hemmings was not required to maintain a margin account, and,            
          other than the initial fees paid for the program, there was no              
          risk of loss from the purported trading.  Also, unlike other                
          futures transactions, Mr. Hemmings was not consulted when changes           
          were made in these accounts.  Changes in the programs were made             
          under a power of attorney held by the sponsor of the programs.              
               The Hemmingses settled most of the issues involving the                
          taxable years 1978 to 1980.  They conceded the losses claimed               
          from the ACLI and ELMS transactions and paid approximately                  
          $3,500,000 in taxes and interest.  In deciding to settle the tax            
          issues arising from the ACLI and ELMS transactions, Mr. Hemmings            
          became convinced that the purported transactions never took                 
          place.                                                                      




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