- 3 - U.S. Treasury bond futures contracts for his own account on the trading floor of the CBOT. In 1994, the Commodity Futures Trading Commission (CFTC) initiated an investigation of petitioner regarding alleged improper trading conduct, the specifics of which are not in the record. Petitioner remained a member of the CBOT. Because of the ongoing CFTC investigation, however, in 1994 while the investigation was pending, petitioner chose to conduct his trades through a floor broker rather than conduct his trades directly on the trading floor of the CBOT. In 1994, petitioner realized a total of $1,541,926 in net gains relating to his trading in commodities futures contracts through the broker, and petitioner paid more than $89,000 in commissions to the floor broker. On November 21, 1994, as a result of the settlement with the CFTC of the above investigation, petitioner was allowed to trade directly on the floor of the CBOT under the supervision of another trader. On his timely filed 1994 Federal income tax return, petitioner treated the total $1,541,926 in net gains (that petitioner realized in 1994 relating to his trading activity in commodities futures contracts through the broker) as capital gains and reported them on Schedule D, Capital Gains and Losses, of his income tax return. On his Schedule C, Profit or Loss fromPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011