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exhibits are incorporated herein by this reference. At the time
the petition was filed, petitioner maintained a permanent legal
address in Waynesville, North Carolina.
1. Dealer, Trader, or Investor
During the years in issue, petitioner was employed full time
as an information systems engineer--first by General Electric Co.
until August 1988 and then by Systems Planning Corp. until March
1989. Petitioner began investing in the stock market in 1975.
Until June 1987, petitioner considered himself an investor, after
which he considered himself a "securities trader and dealer".
Beginning with his 1987 individual Federal income tax return,
petitioner reported all activity relating to his stock purchases
and sales, such as dividend income, investment expenses, and
gains and losses, on Schedule C.
Petitioner considered his stock activity a part-time
endeavor during his full-time employment with General Electric
Co. and Systems Planning Corp. Petitioner committed
approximately 10-20 hours of his free time each week to this
activity. Petitioner listened to the radio for stock reports and
prices during his lunch hour. During the evenings at home, he
studied newspaper quotations, books, magazine articles, ran
commercial software on his computer, and analyzed stock market
data. Petitioner gave his trading instructions to his broker in
the morning, prior to the market opening.
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