- 54 - Her stock forwards account shows a similar pattern, with trades that rolled gains from 1981 and 1982 into taxable status in 1984: December 1981 Realized loss ($699,300) December 1981 Unrealized gain 700,180 January 1982 Realized gain 701,750 December 1982 Realized loss (100,051) December 1982 Unrealized gain 105,498 January 1983 Realized gain 328 December 1983 Realized gain 218,468 December 1983 Unrealized loss (211,116) January 1984 Realized gain 103,376 The evidence in these cases provides less detail concerning Leema's trading than is available for the individual petitioners. Leema and Merit had taxable years ending on June 30. The available evidence shows losses and gains incurred through Leema's subsidiary, Merit, as follows: T-bonds: June 1980 Realized loss ($846,736) June 1980 Unrealized gain -0- July 1981 Realized gain 1,091,479 T-bills: June 1981 Realized loss 3,227,296 June 1981 Unrealized gain 3,330,690 July 1981 Realized gain 2,774,360 Information regarding Merit's stock forwards trading is sketchy. Its tax returns reveal T-bill option trading income of $2,766,085 but stock forwards "cancellation fee" deductions of $2,845,358. Petitioners urge that their intentionally realized first-year losses on their spreads were merely part of investment programs that extended over several years. Their evidence, however, falls farPage: Previous 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 Next
Last modified: May 25, 2011