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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 and
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