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The number and frequency of the purchases and sales of
commodities and options in the above-described accounts are as
follows:
Petitioner’s Joint Mrs. Corrigan’s Total Sales
Year Account Account Account or Purchases
1987 23 5 51 79
1988 39 37 4 80
1989 19 0 22 41
1990 0 0 3 3
1991 11 0 21 32
Petitioner claimed that his dealing in options and
commodities constituted a trade or business.
OPINION5
Petitioner challenged numerous adjustments determined by
respondent for 1987 through 1991. After trial, petitioner
requested and was permitted several extensions of time for the
filing of his factual and/or legal arguments with the Court.
Ultimately, petitioner did not file a posttrial brief to assist
the Court in better understanding his position regarding the
errors that he alleged exist with respect to respondent’s
determinations.
I. Settlement and Release of $325,000 Debt
During 1984 petitioner borrowed $390,000 from Prudential.
Petitioner repaid $65,000 and continued to owe $325,000 as of
1985, when he resigned his position with Prudential. Prudential
5 Sec. 7491 does not apply because the audits for 1987
through 1991 occurred before 1998.
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