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were executed by Mr. Resser for account QRF during the remainder
of 1982.
For taxable year 1982, petitioners reported wage income of
$251,413, consisting of $236,550 earned by Mr. Resser as a risk
manager for Rialcor and $14,863 of compensation earned by Mrs.
Resser. Mr. Resser also earned $42,975 as consulting and
director fees.
For taxable year 1982, petitioners reported a $250,671 loss
from stock option investments on a Schedule C attached to their
Federal income tax return. Included in the Schedule C loss were
$804,336 of losses and $555,176 of gains from stock option spread
transactions from account QRF.7 In addition to the $249,160 of
loss ($555,176 minus $804,336), a $1,511 deduction for expenses
related to Mr. Resser's trading activity was claimed, which
resulted in the Schedule C net loss of $250,671.
Petitioners' 1982 taxable income was computed as follows:
Income or Loss Item Amount
Wages or salaries $251,413
Interest income 46,843
Refunds of State taxes 3,737
Schedule C loss (250,671)
Schedule E loss (28,599)
Consulting, director fees 42,975
65,698
Schedule A and Schedule W
deductions, exemptions (62,172)
1982 Taxable income $ 3,526
7 This also includes the Superior Oil Corp. gains realized
in February 1982 which were not challenged by respondent.
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