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commodities account in petitioner’s name at Refco, Inc. (Refco),
a trading clearinghouse. Mr. Campbell stated that he transferred
approximately $100,000 to petitioner’s account every few months.
Petitioner’s Assets and Liabilities
On or about February 1, 1983, the Campbells purchased a home
in Naperville, Illinois, for $321,000. On August 16, 1982, Mr.
Campbell had transferred $1 million to petitioner’s personal
account from profits in petitioner’s Refco account by securing a
check from Refco issued to petitioner for that amount.
Petitioner used those funds to purchase the home and several
certificates of deposit. The house was not subject to a mortgage
loan. Petitioner and Mr. Campbell resided in the Naperville home
from February 1 through December 31, 1983. Sometime in 1990, the
Campbells sold one of two lots on which the Naperville home was
located for approximately $165,000. In 1993, they sold the
remaining lot for approximately $393,000. In 1990, the Campbells
purchased a home in petitioner’s name in Lampe, Missouri (the
Lampe home), for approximately $181,000. The Lampe home has
remained an asset exclusively owned by petitioner. They used
some of the proceeds from the sale of the Naperville property to
purchase the Lampe home.
As of the end of the taxable year 2000, petitioner had an
individual retirement account with a fair market value of
$35,833. As of August 14, 2003, there has been no mortgage or
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