- 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.
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