Leema Enterprises, Inc. - Page 54




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          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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Last modified: May 25, 2011