i feel like a smuck, do you?, page-35

Thanks Nursery, I do understand that only profits, or losses, are assesable for tax. Reading your post suggested you apply short term losses (those incurred in less than a year), against capital gains. This is clearly a no no as revenue losses cannot be offset against capital gains.

The structure you describe sounds interesting, and having a masters in tax law piques my interest. Trust you have advice on it as you wouldn't want the commissioner invoking Part IV A.