EFTA02711176

From: Richard Joslin Sent: Thursday, July 3, 2014 6:29 PM To: jeffrey E.; lawrence delson Subject: margin trade vs option Attachments: Switch From Treating Basket Transactions....pdt CCA 201426025 - Section 446 - General Rule for Methods of Accounting.pdf As fyi- thought you mi=ht find of interest Client put 10% down; b=oker financed 90% - economically similar to - in-the-money cash settled ca=l option with premium = 10% of notional. Under option, tax P&L = n=t cash; under financed trade, tax P&L gains, losses, expenses. IRS challenged and tre=ted as change in accounting method 1 EFTA_R1_02124659 EFTA02711176