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references are to the Tax Court Rules of Practice and Procedure.
All dollar amounts have been rounded to the nearest dollar.
FINDINGS OF FACT
Some facts are stipulated and are so found. The stipulation
of facts, with accompanying exhibits, is incorporated herein by
this reference.
At the time the petition was filed, petitioner resided in
Shanghai, China.
Petitioner’s Purchases and Sales of Securities
During 1999, petitioner maintained two brokerage accounts
for conducting securities transactions: one with Charles Schwab &
Co., Inc., and one with Datek Online Brokerage Services, which
subsequently merged with Ameritrade. During 1999, through those
two accounts, petitioner initiated 323 transactions involving the
purchase or sale of securities (including short sales), broken
down by month as follows:
Month Number of Trades
January 12
February 133
March 145
April 25
May 4
July 4
Petitioner held most of those securities for less than a
month, and petitioner’s 1999 short sales were generally covered
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Last modified: May 25, 2011