Leema Enterprises, Inc. - Page 52




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          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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