-91- The adjusted midmarket method generally did not include an adjustment for the dealer’s profit margin. Nor did FNBC’s implementation of that method include such an adjustment. V. Los Alamos Project In 1994, the Commissioner entered into a contract with the Los Alamos National Laboratory under which the Los Alamos scientists (including quantum physicists and mathematicians) were to develop in the form of software a sophisticated model to assist the Commissioner in valuing interest rate swaps, currency swaps, and other financial derivative products for which mark-to- market reporting was required under section 475. This software was intended to produce a narrow range of values for swaps that a revenue agent could use as a litmus test for ascertaining whether a more thorough audit would be necessary as to a dealer’s valuation of its swaps. The Commissioner contemplated that a more detailed audit would be required if the dealer’s valuation fell outside the range of values. The Los Alamos team was to address during the first 12 months of the project the following nine issues: 1. Address security and disclosure issues. –- Some of the data required in the model development must use sensitive unclassified information about taxpayers’ market transactions. Procedures must be put in place to handle these requirements. 2. Determine how the various forms of tax information data are handled and its impact on models. –- For example much of the data on transaction is only available in paper format. In this casePage: Previous 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 Next
Last modified: May 25, 2011