Robert E. Corrigan - Page 12

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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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