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Respondent determined that Native American Finance was not a
trade or business and disallowed the claimed cost of goods sold
in 1997 and the deductions for the claimed expenses for 1997 and
2000. The determination shifted the 1997 and 2000 reported gross
receipts from Schedule C to line 21, "Other Income", of the Form
1040, U.S. Individual Income Tax Return.
Capital Gains
On January 20, 1999, Mrs. Doxtator purchased 600 shares of
American Pad & Paper Co. for a total cost of $650.50 which she
sold on April 21, 1999, for net proceeds of $989.46. On February
12, 1999, Mrs. Doxtator purchased 200 shares of Williams Coal
Seam Gas for $1,850.50 which she sold on March 19, 1999, for net
proceeds of $1,986.93. On March 19, 1999, Mrs. Doxtator
purchased 400 shares of Burnham PAC PPTYS, Inc., for $4,188 which
she sold on April 23, 1999, for $4,586.84. On April 27, 1999,
Mrs. Doxtator sold 100 shares of Jevic Transportation, Inc., for
net proceeds of $899.46.4 On May 4, 1999, Mrs. Doxtator bought
200 shares of Arkansas Best Corp. Del. for $7,263 which she sold
on July 6, 1999, for net proceeds of $7,249.25. On July 12,
1999, Mrs. Doxtator sold 1 share of Patriot American Hospitality,
that was received pursuant to a cash merger on June 20, 1999, for
net proceeds of $11.61.
4 The record does not indicate the cost or acquisition date
of this stock.
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