- 5 - indirectly through the allowance that Mr. Campbell would deposit in her bank account in order for her to be able to write the family checks. Even when petitioner bought the Naperville home in 1982, she did so with money that Mr. Campbell gave to her from the profits in her account, rather than withdrawing the funds herself. Petitioner had no knowledge of the trading activities, nor was she aware of the balance in the account at any given time. Mr. Campbell’s Trading Activities Mr. Campbell directed trading activities for his own account and the accounts of others, including one or more accounts owned by petitioner. During the taxable year 1983, Mr. Campbell held a 5-percent partnership interest in Refco Foods, Ltd., a business that bought, resold, and hedged meat products. Refco Foods, Ltd., is a distinct entity from Refco, which as previously discussed is a trading clearinghouse in which Mr. Campbell has no ownership interest. At the end of the taxable year 1983, Refco Foods, Ltd., had a loss of approximately $2.6 million in its futures spread income account. During the same year, Mr. Campbell operated a business called Refco Foods Too, a meat commodities trading company, as a sole proprietorship. Refco Foods Too had net losses of approximately $600,000 for the taxable year 1983. In addition, during the taxable year 1983, Mr. Campbell was the president andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011