Leema Enterprises, Inc. - Page 36




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          consolidated Federal income tax returns filed by Leema, Merit's             
          parent corporation.  Leema and its subsidiaries, including Merit,           
          report their income on the basis of a fiscal year ending on June            
          30.  For taxable years 1980 through 1982, respondent disallowed             
          losses reported by the Leema consolidated group with respect to             
          Merit's transactions that gave rise to realized losses.                     
                    (1)  1980 Transactions:  T-Bond Options                           
               Beginning in June 1980, Merit's T-bond option account, No.             
          111, engaged in two separate trading series, each of which featured         
          the open-switch-close pattern of generating tax losses.                     
              On June 11, 1980, Merit set up four straddles involving puts           
          and calls in T-bonds in trade No. 210. On June 19, 1980, 8 days             
          later, Merit set up four additional straddles involving T-bond puts         
          and calls in trade No. 211.  Six days later, Merit closed out the           
          purchased call contracts in a "switch" in trade No. 211.  The               
          switch transactions generated short-term capital losses of                  
          $411,500.1713 for Merit's 1980 taxable year.  On June 27, 1980, 2           
          days later, Merit closed out the purchased call contracts in trade          
          No. 210 by selling offsetting call contracts.  This second switch           
          in the T-bond options generated additional short-term losses of             
          $435,235.  For its 1980 taxable year, Merit's total T-bond option           
          losses were $846,735.67.  There were no realized gains.                     





               13   One trade in the switch transactions which gave rise to           
          these losses generated income of $266.09.                                   

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