Stanley and Jean Cohen - Page 7

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               The results of petitioner's securities trading for each of             
          the years at issue were reported on Schedule C using a method               
          that tracked changes in an aggregate trading account.  The ending           
          balance of this account was reported as "gross receipts" for the            
          taxable year, while the sum of the initial balance plus losses              
          incurred during the taxable year was reported as "cost of goods             
          sold".  The Schedule C for each year showed a net loss equal to             
          the excess of the amount of cost of goods sold and certain                  
          business expenses over gross receipts (gross receipts were not              
          reported for 1985).  No information provided on the returns                 
          identified what "gross receipts" and "cost of goods sold"                   
          represented.  The reported amounts, taken from the worksheets               
          that Leuschner had received from petitioner, overstated the                 
          actual losses by $184,598 for 1985, $76,910 for 1987, and $46,281           
          for 1988.  The Forms 1040 for each year described petitioner's              
          occupation as "trader" and the Schedules C for 1985 and 1988                
          further identified the business activity to which the cost items            
          were attributable using simply the word "trading".  The type of             
          asset traded was not disclosed.  In addition, for 1985 and 1987             
          petitioners reported on Schedule C certain expenses that should             
          have been reported on Schedule A, and they claimed losses from              
          partnerships and S corporations in amounts that exceeded                    
          petitioner's basis and amount at risk by $5,444 for 1985,                   
          $154,468 for 1987, and $379,613 for 1988.                                   





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