The taxpayer traded foreign currency options, with its principal option activity being the writing of European-style puts and calls. Rip J found that the options contracts, if purchased by the taxpayer, were held as inventory, and thereby could be valued under s. 10 (noting, at paras. 121-2) that, contrary to GAAP, inventory for ITA purposes can include intangible property and, at para. 124 that "there is no requirement that property must be held for sale to qualify as inventory.") However, the contracts which the taxpayer instead had written were liabilities rather than property, and thus not inventory (stating, at para. 130 that "until maturity or settlement, the writer is liable to the purchaser."
See summary under s. 10(1).