- 34 -                                         
               Ms. Rivera's reported ordinary losses from Merit trading               
          activities in 1981, compared to her adjusted gross income in the            
          same year, were as follows:                                                 
               A.G.I.         Merit     A.G.I.    Loss % of A.G.I.                    
          Per Return     Losses            w/o Loss    w/o Merit Loss                 
          $13,9271      ($63,176)       $77,103          82%                          
               1    Ms. Rivera's adjusted gross income reflects ordinary losses       
          from Merit trading totaling $63,176.  This amount includes                  
          cancellation fees and $17,426 identified as "options" on her                
          return.  The capital losses appear to have been incorporated in her         
          loss carryover.                                                             
                    (3)  1982 Transactions                                            
               In January 1982, Ms. Rivera recognized the unrealized gains            
          from her stock forwards account, now totaling $701,750.  She                
          withdrew her cash balance of $203,850, then deposited $10,000 in            
          April and $14,035 in May.  There was no trading in her account              
          until July 1982.  At that time, her trades generated capital losses         
          of $245,484.  In October, the account incurred capital losses of            
          $313,483, and in December it incurred additional capital losses of          
          $209,385, for a total of $768,352.  These losses exceeded the               
          $701,750 capital gains realized in the previous January by $66,602.         
          She also incurred cancellation fees of an additional $35,877.  The          
          amount of the cancellation fees, $35,877, was added to her cash             
          account.  For 1982, all of her combined cancellation fees and               
          losses from the account exceeded her gains--including an amount of          
          $2,427 as "other" income--by $100,052.  The account also retained           
          an unrealized gain of $105,498 into 1983, plus a capital loss               
          carryover of $123,570.  These transactions, when compared to her            
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