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sale to customers in the ordinary course of his trade
or business * * *
Petitioner focuses on this text and argues that his Treasury
securities were not capital assets. According to petitioner,
even if he did not hold the Treasury securities for sale to
customers, the securities were "stock in trade" or "other
property of a kind which would properly be included in * * *
[his] inventory * * * if on hand at the close of the taxable
year". Petitioner asserts that he bought the Treasury securities
for resale, which, he concludes, means that the securities were
stock in trade or inventory. Petitioner asserts that an ordinary
loss arises from the sale of property in an everyday activity,
such as his security trading, in which there are short holding
periods, a frequency and volume of sales, and regular interaction
with buyers. Alternatively, petitioner argues, he held the
Treasury securities "primarily for sale to customers in the
ordinary course of his trade or business". Petitioner asserts
that his customers were his primary dealer counterparts;
according to petitioner, the meaning of the word "customer"
includes any person with whom he had established business
relationships and with whom he dealt regularly on a
principal-to-principal basis. Petitioner asserts that the fact
that he held his Treasury securities primarily for sale to
customers is evidenced by the fact that B&C bought and held
securities primarily for sale to its customers. Petitioner
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