From: Richard Joslin -4

From: Richard Joslin -4 To: jeffrey E. <[email protected]>, lawrence delson Subject: margin trade vs option Date: Thu, 03 Jul 2014 18:28:53 +0000 Attachments: Switch_ From_ Treating_Basket_Transactions....pdf; CCA_201426025_-_Section_446_- General_Rulefor Methods_of Accounting.pdf As fyi- thought you might find of interest Client put 10% down; broker financed 90% - economically similar to - in-the-money cash settled call option with premium = 10% of notional. Under option, tax P&L = net cash; under financed trade, tax P&L gains, losses, expenses. IRS challenged and treated as change in accounting method EFTA01193902