- 53 -
December 1979 Realized ordinary loss ($77,440)
December 1979 Unrealized gain 78,205
January 1980 Realized capital gain 78,488
November/December
1980 Realized loss (1,200,273)
December 1980 Unrealized gain -0-
January 1981 Realized gain 11,115,550
1 Peng Partners indicated the same open-switch-close patterns
which are indicative of a lack of economic substance. Dr.
Richartz's distributive share of Peng Partners' T-bill option losses
are thus indistinguishable from his personal losses from T-bill
option trading.
The pattern persisted in Dr. Richartz' stock forwards trading:
December 1981 Realized loss ($2,626,320)
December 1981 Unrealized gain 2,656,440
January 1982 Realized gain 2,668,910
As a market maker, Dr. Richartz entered into taxable
transactions at various times in the last half of 1982 and 1983.
The yearend results were as follows:
December 1982 Realized loss ($1,826,589)
December 1982 Unrealized gain 1,857,057
January 1983 Realized gain 668
December 1983 Realized loss (61,807)
December 1983 Unrealized gain 82,054
January 1984 Realized gain 1,642,552
Ms. Rivera's T-bond and T-bill accounts also reflect the
pattern of first-year losses and deferral of gains:
T-bills:
December 1980 Realized loss ($81,001)
December 1980 Unrealized gain 80,985
January 1981 Realized gain 80,956
T-bonds:
December 1980 Realized loss (408,527)
December 1980 Unrealized gain 423,538
January 1981 Realized gain 426,959
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