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Commodity Futures Trading Commission 

CEA CASES 

NAME: ELI WATSON TULLIS 

DOCKET NUMBER: STIPULATION 40 

DATE: OCTOBER 20, 1958 

DOCUMENT TYPE: STIPULATION OF COMPLIANCE 

UNITED STATES DEPARTMENT OF AGRICULTURE 

BEFORE THE SECRETARY OF AGRICULTURE 

In re: Eli Watson Tullis 

Stipulation of Compliance under the Commodity Exchange Act No. 40 

WHEREAS, the Secretary of Agriculture has reason to believe that Eli Watson 

Tullis has violated the provisions of the Commodity Exchange Act (7 U.S.C., 1952 

ed., Chapter 1) and the rules and regulations of the Secretary of Agriculture 

promulgated thereunder by virtue of certain transactions involving the purchase 

and sale of cotton futures, and 

WHEREAS, no complaint with respect to such violations has been issued, and 

WHEREAS, section 0.4(a) of the rules of practice under the Commodity Exchange 

Act (17 CFR 0.4(a)) provides that at any time prior to the issuance of a 

complaint in any proceeding, the Secretary of Agriculture may, in his 

discretion, enter into a stipulation with a prospective respondent whereby the 

latter admits the material facts and agrees to discontinue the acts or practices 

which are intended to be set up as violative of the Act, and 

WHEREAS, the said Eli Watson Tullis is desirous of disposing of this matter 

by entering into such a stipulation, 

NOW, THEREFORE, the said Eli Watson Tullis hereby stipulates and represents 

that the following facts are true: 

1. Eli Watson Tullis is a member of the New Orleans Cotton Exchange and is 

registered as a floor broker under the Commodity Exchange Act. 

2. Section 4c of the Commodity Exchange Act (7 U.S.C., 1952 ed., § 6c) 

provides in part as follows: 

It shall be unlawful for any person to offer to enter into, enter into, or 

confirm the execution of, any transaction involving any commodity, which is or 

may be used for (1) hedging any transaction in interstate commerce in such 

commodity or the products or byproducts thereof, or (2) determining the price 

basis of any such transaction in interstate commerce in such commodity, or (3) 

delivering any such commodity sold, shipped, or received in interstate commerce 

for the fulfillment thereof -- 

(A) if such transaction is, is of the character of, or is commonly known to 

the trade as, a "wash sale", "cross trade", or "accommodation trade", or is a 

fictitious sale; 

3. Section 1.38 of the rules and regulations under the Commodity Exchange Act 

(17 CFR, 1954 Supp., 1.38) provides as follows: 

All purchases and sales of any commodity for future delivery on or subject to 

the rules of a contract market shall be executed openly and competitively as to 

price by open outcry or posting of bids and offers or by other equally open and 

competitive methods, in the trading pit or ring or similar place provided by the 

contract market, during the regular hours prescribed by the contract market for 
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trading in such commodity: Provided, however. That this requirement shall not 

apply to such transactions as are executed in accordance with written rules of 

the contract market which have been submitted to and not disapproved by the 

Secretary of Agriculture, specifically providing for the noncompetitive 

execution of such transactions. 

4. On September 10, 1958, Eli Watson Tullis, acting for his own account, made 

the following transactions in cotton futures traded on the New Orleans Cotton 

Exchange with Arthur W. Hyland who took the opposite side of each transaction 

for his own account: 

Bought Sold 

No. of Bales Future Price No. of Bales Future Price 

(Cents) (Cents) 

500 Oct. 1958 35.40 500 Oct. 1958 35.40

500 July 1959 34.46 500 July 1959 34.45

500 July 1959 34.46 500 July 1959 34.45

2,000 July 1959 34.49 2,000 July 1959 34.48

500 Oct. 1959 32.07 500 Oct. 1959 32.07

2,000 Oct. 1959 32.07 2,000 Oct. 1959 32.07

The above transactions were "wash sales" made in violation of section 4c(A) 

of the Commodity Exchange Act (7 U.S.C., 1952 ed., § 6c(A)) and were not made 

openly and competitively in the trading ring, and were in violation of section 

1.38 of the rules and regulations under the Commodity Exchange Act (17 CFR, 1954 

Supp., 1.38). 

In addition to admitting the foregoing facts, the said Eli Watson Tullis 

hereby agrees to discontinue all such acts and practices and to refrain from all 

other acts and practices which are in violation of the Commodity Exchange Act or 

the rules and regulations thereunder, and further understands that this 

stipulation shall be admissible as 

evidence of acts and practices in violation of the rules and regulations under 

the Commodity Exchange Act in any proceeding based upon transactions in addition 

to those referred to in paragraph 4 hereof which may hereafter be brought by the 

Secretary of Agriculture against the said Eli Watson Tullis under the provisions 

of the said Act. 

Done at New Orleans, Louisiana, this 

20th day of October 1958. 

/s/ Eli Watson Tullis 

Witnessed by: 

/s/ William D. Espy 

/s/ John T. Heavey 

LOAD-DATE: June 16, 2008 
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