- 52 -
centerpiece" of tax straddles--the closing of positions which
produce losses for the first year and the movement of the offsetting
gain to subsequent years by rollovers. Krumhorn v. Commissioner,
103 T.C. 29, 51 (1994); Glass v. Commissioner, supra. The Merit
trades again show consistent patterns of such rollovers, with
realized losses being taken in the first year and unrealized gains
being rolled over so that they will not be taxed until the next
year, or even later years.
Mr. Keeler's trading in the Merit T-bill program produced the
following deferrals and rollovers:
December 1980 Realized loss ($689,600)
December 1980 Unrealized gain 667,685
January 1981 Realized gain 651,320
Trading in his stock forwards account showed a similar pattern,
rolling gains from 1981 and 1982 into taxable status in 1984:
December 1981 Realized loss ($8,250,260)
December 1981 Unrealized gain 8,207,410
January 1982 Realized gain 7,984,320
December 1982 Realized loss (9,955,447)
December 1982 Unrealized gain 9,851,790
January 1983 Realized gain -0-
December 1983 Realized loss (35,230)
December 1983 Unrealized gain (2,520)
January 1984 Realized gain 9,588,496
Dr. Richartz's T-bill activity showed the following
patterns:
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