- 13 - Merit initially organized its option customers into two groups--the A side and the B side. Members of the A side traded only with members of the B side, and vice versa. Almost all of the trades for the 1979-80 tax year demonstrate what has been called an open-switch-close pattern. Six sets of orchestrated trades or trading sequences took place in the 1979 Merit T-bill option market. In each of these sequences, only 3 trading days were involved. The first occurred in the second week of December 1979, when all the investors "opened" a position by buying or selling an option spread from members of the other side. On December 28, 1979, all participants "switched" by buying or selling options that would offset the loss legs of their opening positions. In so doing, every investor in the T-bill program incurred a loss that was an ordinary loss for tax purposes. Then, on January 4, 1980, in the subsequent taxable year, the investors acquired offsetting positions to close out their gain legs--or they allowed their options to expire unexercised. They incurred gains that approximated their taxable losses incurred a few days earlier, in the prior taxable year. In 1980-81, trading in the Merit T-bill accounts was slightly more complex, but 23 of 27 trading sequences followed the open- switch-close pattern which took place shortly before and shortly after the end of the investors' taxable years. (...continued) figured in, he ended up with an overall economic loss of $205,930 in the trade sequence.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011