- 6 -
telephone, on behalf of a messenger service located in New York
City, for which she was compensated approximately $200.
During December 1980, petitioner was hired as a stockbroker
trainee in New York. In order to prepare for the "series seven"
stockbroker examination required for her employment, petitioner
studied about stocks and bonds at home. Prior to passing the
exam, petitioner answered the telephones for her employer.
During the early part of 1981, petitioner passed the exam and
obtained her stockbroker license. Subsequently, petitioner
"cold-called" potential clients to sell them stocks and bonds.
Neither petitioner's studies nor her work specifically included
commodities tax straddles.
During the years in issue, Mr. Crowley was a partner in TSM
Associates, Sinclair Securities Company, and APEX Associates,
which were partnerships that had engaged in commodities straddle
transactions involving Treasury bill options. Mr. Crowley, as an
employee in James Sinclair Trading Corporation, arranged
commodities straddle transactions for investors seeking "tax-
sheltered investments".
Petitioner was aware of Mr. Crowley's position as a
"commodities trader". Petitioner accompanied Mr. Crowley at
several commodities seminars during which she "milled about" at
the back of the room, "drifted" in and out of the seminar rooms,
and socialized with other wives attending the seminars.
Petitioner attempted to attract clients for her husband at the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011