- 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 far
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