Laureys v. Commissioner
United States Tax Court
P, a member of the CBOE and an appointed market maker in certain CBOE options, engaged in various option spread transactions. Held, offsetting positions in options do not constitute a "similar arrangement" under sec. 465(b)(4), I.R.C. 1954, as amended.
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P, a member of the CBOE and an appointed market maker in certain CBOE options, engaged in various option spread transactions. Held, offsetting positions in options do not constitute a "similar arrangement" under sec. 465(b)(4), I.R.C. 1954, as amended. Held, further, R's expert report would not be received in evidence; P entered into the transactions for the primary purpose of profit; the transactions were for P's own account and were not dealer activity eligible for ordinary loss treatment.
1Opinion of the Court
Cohen, Judge:
Respondent determined deficiencies of $310,068 and $171,828 in petitioners’ Federal income taxes for 1980 and 1982, respectively, resulting from disallowance of losses claimed by petitioner Frank J. Laureys, Jr. (petitioner), from certain option spread transactions. The questions presented are (1) whether offsetting positions in such option transactions were a “similar arrangement” protecting petitioner against loss within the meaning of section 465(b)(4);1 (2) whether the transactions were not entered into primarily for profit or lacked the substance necessary for recognition…
2Cases cited37 opinions
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