Gary K. Bielfeldt and Carlotta J. Bielfeldt - Page 12

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          price.  B&C's retail customers in Treasury securities were long-            
          term clients, personal friends, employees, and friends of                   
          personal friends.  The only account holders at B&C, other than              
          petitioner, who traded Government securities were customers of              
          B&C, not of petitioner.                                                     
               B&C's offices are in Peoria and Chicago, Illinois, and                 
          employees in both offices engage in proprietary trading.  The               
          Peoria office is primarily responsible for customer relations,              
          including identifying and soliciting customer prospects,                    
          preparing customer account agreements, responding to customer               
          inquiries, and administering the managed account program.  The              
          Chicago office serves "back office" functions, clearing all                 
          Treasury securities, futures, and other trades and handling                 
          accounting, customer credit, and regulatory compliance.                     
          Petitioner works out of the Peoria office, and B&C pays the rent            
          on the space that he uses.  Petitioner used this space to engage            
          in his personal trading, which included the trading of futures              
          contracts, stocks, corporate bonds, and all three types of                  
          Treasury securities.  Petitioner transacted his personal trades             
          through B&C, and B&C cleared these trades and performed the                 
          required bookkeeping for them.  Petitioner used B&C's video                 
          screens and other market information services to assist him with            
          his Treasury securities cash trading, and he used B&C's                     
          telephones and direct lines to primary dealers.  An employee in             





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