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from transactions in securities on Schedule C of their 1990
Federal income tax return.
During the years in issue, petitioner purchased and sold
securities and futures contracts for his own account only, and
not for the account of others. With respect to petitioner's
transactions in securities and futures contracts, petitioner made
all purchases from, and all sales to, registered broker-dealers.
Petitioner spent a substantial amount of time each week
researching, reading trade publications, and devising trading
strategies. This activity was conducted from petitioner's home.
Petitioner did not have an established place of business for
conducting securities transactions for his own account. During
such time petitioner did not have a license to be a dealer in
securities and did not advertise himself as a dealer in
securities, nor did he maintain any customer accounts.
Petitioner was charged a commission on every security
transaction made on his behalf during the years in issue. All of
the gross receipts reported by petitioners on Schedule C of their
Federal income tax returns for 1989 and 1990 were derived from
sales of securities to broker-dealers, and none of the gross
receipts were derived from commissions from the sale of
securities to or on behalf of individual investors.
The dollar amounts of the losses from transactions in
securities and futures contracts reported by petitioners on their
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