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FINDINGS OF FACT
A. Petitioner
Petitioner resided in Holden, Louisiana, when she filed the
petition.
B. Petitioner’s Brokerage Account
Petitioner had a brokerage account at Dain Rauscher, Inc.
(Dain Rauscher), in 1996, 1997, and 1998 (1996-98). Predecessor
entities of Dain Rauscher include Everen Clearing Corp., Regional
Operations Group, Interra Clearing Services, and Personal
Retirement Planning Group. We refer to these predecessor
entities as Dain Rauscher.
Petitioner held stocks, bonds, and mutual fund shares in her
account in 1996-98. Her brokers at Dain Rauscher sold stocks,
bonds, and mutual fund shares on her behalf during those years
and reported those sales to respondent on Forms 1099. Petitioner
paid margin interest to Dain Rauscher totaling $1,738.04 in 1996,
$1,844.25 in 1997, and $3,764.40 in 1998. Petitioner received
monthly statements from Dain Rauscher during those years that
showed purchases and sales of stocks, bonds, and mutual fund
shares on her behalf, and the proceeds she received from those
sales, as well as interest, dividends, and capital gain
distributions she received.
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