Apple is increasingly pushing its AppleTV through a low-cost device strategy, while Microsoft is leveraging its position in the gaming market with the Xbox to become more a full fledged player in digital distribution.
The object of strategyis to position the business in a place where the barriers are so high that there is little competition and excess profits are more or less guaranteed over long periods of time.
In particular, it may be difficult to determine whether principal risk has been retained because (i) the retention of such risk is necessary to provide intermediation and liquidity services for a relevant financial instrument or (ii) the positionis part of a speculative trading strategy designed to realize profits from price movements in retained principal risk.
Almost as bad as noncomputable problems are intractable ones (such as determining whether there isa guaranteed winning strategy for an arbitrary chess position), which cannot be solved in a reasonable amount of time.
Stevenson is fighting the claim in U.S. Tax Court, but if the IRS sticks by its position and is upheld, it threatens astrategy apparently used by many wealthy individuals to raise cash and hedge risk while deferring taxes.