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his agent and instrumentality for purposes of trading the
Treasury securities in Account 2900, the facts at hand do not
support such a conclusion. The fact that petitioner personally
owned his Treasury securities, that he traded them for his own
account, that he did not have a separate place of business to
conduct his trading, and that his only source of income from his
trading depended on an increase in value all militate against
categorizing him as a dealer. See Marrin v. Commissioner,
147 F.3d at 151; Kemon v. Commissioner, supra at 1032.
Second, petitioner's primary intent in trading Treasury
securities was inconsistent with that of a dealer. A dealer
purchases securities intending to profit primarily from selling
the securities at an increased price that represents remuneration
for working as a middleman and performing the usual services of
retailer or wholesaler of goods. Kemon v. Commissioner, 16 T.C.
at 1032-1033; see Estate of Hall v. Commissioner, 29 B.T.A. 1255,
1259-1260 (1934), affd. sub nom. Commissioner v. Stevens, 78 F.2d
713 (2d Cir. 1935); see also MacAdam v. Commissioner, T.C. Memo.
1991-410. Petitioner, by contrast, aimed to reap a profit from
an increase in value caused by a favorable fluctuation in
interest rates, and, but for such a favorable fluctuation, he
would not have reaped any meaningful profit at all. Interest
rates change daily, and petitioner speculated that the short-term
course of those rates would be consistent with the course that he
predicted, which, in turn, would increase the value of his
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