Stephen and Jane Marrin - Page 4

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          in his price being displayed on the appropriate securities                  
          exchange.  Petitioner's goal in employing the "on the book" bid             
          and asked method was to derive a profit from the "spread"                   
          prevailing between bid and asked prices on the market.                      
          Petitioner also purchased and sold futures contracts during 1988.           
               Petitioners reported all of their transactions in securities           
          and futures contracts on Schedule D of their 1988 Federal income            
          tax return as capital gains and losses, claiming a net capital              
          loss of $87,377 from such transactions.                                     
               In 1989, petitioner continued to serve as a registered                 
          securities principal for Cadre until March of that year.                    
          Petitioner was then unemployed until November 1989, when he began           
          working for Overseas Shipyards, Inc. (Overseas), shipyard                   
          representatives providing ship building and repair services.                
          Petitioner served as a full-time employee of Overseas, working              
          approximately 35 hours a week.  Petitioner's position with                  
          Overseas did not involve dealing in securities.                             
               Also during the 1989 taxable year, petitioner received a               
          $100,000 pension distribution (from which no Federal income tax             
          was withheld).  In addition, petitioners reported as income on              
          their 1989 Federal income tax return $35,056.13 in wages, $5,635            
          in unemployment income, and $6,441 in interest and dividend                 








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