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1987 through 1991. A third Smith Barney account was held in Mrs.
Corrigan’s name only during the same period. Petitioner was the
account executive for each of these three accounts.
Petitioner purchased and sold options and commodities
through these accounts that resulted in both gains and losses.
Petitioner used the account in his name (account No. 06K-153400)
to buy and sell options and commodities during the years 1987
through 1989, and 1991. Petitioner incurred the following net
gains and (losses) from trading in the account solely in his
name:
Year Net Income/(Loss)
1987 $116,185
1988 (4,704)
1989 25,845
1991 27,375
Petitioner bought and sold commodities and options through
the joint account (account No. 06K-151106) with Mrs. Corrigan
during 1987 and 1988. Petitioner’s share of gains and (losses)
from the joint account were as follows:
Year Net Income/(Loss)
1987 $7,243
1988 (22,163)
Petitioner was the account executive for the third account
(account No. 06K-127531), which was solely in Mrs. Corrigan’s
name. The transactions in that account and the amount of gains
and losses are not those of petitioner.
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