I didn't read that in the sec complaint. She kept two valuations (which she published to investors) : realized vs unrealized and standard nav. Unrealized is wrong but that's just accounting (similar to tax loss selling around New Years). The she put on calendar spreads that produced no net gain or loss but created two taxable events (a gain and a loss). Nav isn't affected as the two taxable events offset each other but they created a fee for her.