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                    (2)  1981 Transactions                                            
                         (a)  T-Bond Options                                          
               In its next taxable year, Merit closed out its remaining T-            
          bond option contracts and ended its participation in the T-bond             
          program.  These transactions generated short-term capital gains of          
          $1,091,479.16, or an apparent overall gain on T-bond trading of             
          $244,742.                                                                   
                         (b)  T-Bill Options                                          
               Merit's trading in T-bill options began later in Merit's 1981          
          taxable year.  Merit used four accounts.                                    
               By far the largest of Merit's T-bill trading volume--hundreds          
          of trades with many of its customers--occurred in account No. 219.          
          Merit opened account No. 219 on December 26, 1980, with 62 trades           
          which constituted 31 spread transactions.  Merit's only taxable             
          transactions during the calendar year occurred 4 days later, on             
          December 30, 1980.  In one of two switch transactions, Merit                
          realized a gain of $50,050 in a switch of 11 T-bill option                  
          contracts with a customer identified as RPV.  The other transaction         
          yielded a loss of $18,236 in a trade with G & G Associates.                 
               Many of the trades involving account No. 219 terminated early          
          in January 1981, when Merit's customers realized the corresponding          
          gains that related to their December losses and claimed deductions          
          in their 1980 taxable years.  By January 7, 1981, Merit's                   
          cumulative realized gain in account No. 219 stood at $6,598.                
          Account No. 219 remained inactive until May, and its realized gain          
          figure remained at $6,598 until June 30, 1981.  On that date, the           
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