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believe that petitioner could have so exceeded his lines of
credit with the credit card companies that he was able to make
such purchases. Petitioner reported a $14,691 net short-term
loss from the sale of stock and petitioner deducted $3,000 of
that loss in 1996. Despite our misgivings, we shall assume,
arguendo, for purposes of this opinion and in accordance with the
way the case was tried, that the stock sales were in fact made.
During the years in issue, petitioner, in business as
Chameleon Counters, resurfaced countertops for property owners.
In 1993, petitioner began investing money in stocks with an
initial sum of $2,000. Prior to this time, he had no experience
in investing in the stock market.
In 1995, petitioner decided to put more effort into the
stock market activity. As noted, petitioner asserted that he
only invested borrowed money. Petitioner claimed that he had a
credit line of more than $150,000 which he used exclusively for
investing. Petitioner purchased a computer and software.
Petitioner claimed that he spent his days from 8:30 a.m. to 3:00
p.m. on the computer or watching CNBC on the television to get
stock quotes. He also read newsletters on trading. Petitioner
made eight short-term stock sales in 1995 and seven short-term
stock sales in 1996. Petitioner did not invest on behalf of
other people.
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