- 6 - sole shareholder of Campco, Inc., a C corporation. Campco, Inc., reported taxable income of $16,005 in its Federal income tax return for the fiscal year ending August 31, 1983. London Metal Exchange Transaction Sometime in late 1983, Mr. Campbell had discussions with Tom Meyers, the CFO of Refco Foods, Ltd., with respect to what has been described as a London straddle (London straddle). The London straddle was conducted through Van Lessen Richardson & Co. (Van Lessen), a brokerage firm controlled by David Lamb, who was one of the individuals organizing the London straddle. Mr. Campbell stated that he funded the London straddle by transferring approximately $2.6 million from petitioner’s Refco trading account to the Van Lessen account in 1983. Mr. Campbell explained in his testimony that he took roughly $2.6 million from the trading account in his wife’s name at Refco as part of the scheme to generate offsetting losses and he subsequently used those funds to satisfy the losses in Refco Foods Too and Refco Foods, Ltd. Petitioner was not aware that Mr. Campbell withdrew the $2.6 million. Nor did Mr. Campbell consult her about making the withdrawal. The funds were never returned to the account in petitioner’s name and never benefited petitioner. The purported losses generated by the transactions on the London straddle were fictitious. During preparation of the Campbells’ 1983 joint income tax return, Jack Esses, a tax returnPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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