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See Commissioner v. Bollinger, 485 U.S. 340, 344 (1988); see also
Helvering v. Horst, 311 U.S. 112, 116-117 (1940); Blair v.
Commissioner, 300 U.S. 5, 12 (1937). Thus, if a corporation
deals in property as agent for another party, then for tax
purposes the other party, and not the corporate agent, is the
owner. See Commissioner v. Bollinger, supra at 345.
The ordinary relationship of a stockbroker to a customer is
that of an agent to a principal. See Galigher v. Jones, 129 U.S.
193 (1889); 12 Am. Jur. 2d, Brokers, sec. 148 (1997).
Accordingly, a stockbroker is not taxable on the earnings, gains,
or losses generated by transactions in securities it undertakes
for its customer. Rather the customer, as owner of the
securities involved in the transactions, is the taxable party.
The stockbroker nevertheless is required under section 6045 to
file a return setting forth the name and address of each customer
and the gross proceeds of that customer, together with such other
information as may be required by the Secretary. See sec.
6045(a); sec. 1.6045-1(b), Income Tax Regs.
The evidence in this case reveals a straightforward
principal-agent arrangement. Petitioner, as the customer and
principal, engaged Kidder Peabody as his broker and agent to deal
on his behalf with securities he owned. Early in 1991, Kidder
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