- 27 -                                         
          weeks earlier, realizing a net gain of $1,048.  On February 19,             
          1980, he withdrew the resulting $26,048 from his account and ceased         
          trading in that account for several months.                                 
               In August 1980, Dr. Richartz opened a four-participant trade           
          sequence, joining with Leema and an investment adviser, Mr.                 
          Alessandra, to take positions opposite Monex, which had a taxable           
          year ended September 30, 1980.  The trade closed on November 4,             
          1980.  It produced $57,942 in ordinary losses for Dr. Richartz, as          
          well as ordinary losses of $14,955 for Mr. Alessandra.  The trades          
          produced a taxable gain of $67,068 for Monex, but that amount was           
          not recognized until its taxable year ended September 30, 1981.             
               Dr. Richartz performed no other T-bill trading until the end           
          of 1980.  He then participated in four other T-bill sequences, all          
          opened and switched in December 1980.  They followed the familiar           
          open-switch-close pattern.  Opened on December 5 and 17, 1980, none         
          produced taxable gains that year. Instead, when the switches                
          occurred on December 29 and 30, 1980, Dr. Richartz realized                 
          additional losses of $1,142,630.  He carried unrealized gains of            
          $1,155,550 for 5 days into his next taxable year, when these                
          trading sequences closed.  On the next day, he withdrew his cash            
          balance of $105,276, representing a cash loss of $44,724.                   
               Dr. Richartz included an ordinary loss from his T-bill options         
          of $450,901 on his 1980 Federal income tax return.  This loss,              
          compared to his adjusted gross income in the same year, revealed            
          the following:                                                              
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