- 36 - 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.Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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