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other encumbrance on the Lampe home. As of March 3, 2005, the
Lampe home had an approximate fair market value of $183,000.
Petitioner had a balance of approximately $25,000 in her
retirement account at Skaggs Community Hospital as of the date of
trial. In addition, petitioner owned a 1993 Ford Explorer at the
time of trial. Petitioner had no other assets of significant
value.
Petitioner’s Account at Refco
The commodities trading account in petitioner’s name with
Refco was opened in 1979 under her Social Security number by Mr.
Campbell. Mr. Campbell directed the trading activity in this
account. During the taxable year 1983, petitioner had a net gain
of $3,505,382 from trades in her Refco account. Petitioner did
not have knowledge of this gain. The account statements showing
the gains and losses in petitioner’s account were addressed to
petitioner and mailed to her home address; however, petitioner
asserts that she did not open them. Petitioner stated that she
handed over the unopened statements to Mr. Campbell. Petitioner
maintained one or more commodity trading accounts with Refco
until at least December 31, 1989.
Petitioner never had any control over the funds in her Refco
account. An examination of her statements from Refco reveals a
fluctuating balance, evidencing a constant inflow and withdrawal
of funds. The only access petitioner had to her account was
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