- 33 - year, were as follows: T.I. Merit T.I. Loss % of T.I. Per Return Losses w/o Loss w/o Merit Loss ($6,211) ($81,001) $74,790 1108% 1 Ms. Rivera's adjusted gross income was $107,342. In addition to other deductions, she claimed an ordinary loss deduction of $81,001 on T-bill trades, reducing her income pro tanto. She utilized her capital losses as long-term and short-term carryovers. (2) 1981 Merit Transactions (a) T-Bill Options On January 5, 1981, Ms. Rivera closed her T-bill account, realizing a net gain of $80,955. On the entire transaction, she incurred a net loss of $45. Her T-bond account closed the same day, indicating proceeds of $426,959. Compared to her 1980 losses in this account, the overall trading produced a net gain of $18,432. (b) Stock Forwards In November 1981, a stock forwards account was opened in Ms. Rivera's name. This account, No. 667, reflected an initial cash deposit of $150,000; $51,400 was added in December. Trading in that account generated yearend short-term capital losses of $653,550 and yearend cancellation fees of $45,750, or a total loss of $699,300. The account maintained unrealized capital gains of $700,180 into January 1982.12 12 The data in evidence does not make clear whether any of the trades that combined to produce the $699,300 loss was for an economic gain. There is no indication that any such gains were realized.Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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