- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011