Phyllis E. Campbell - Page 16

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          Commissioner, 897 F.2d 441, 444 (9th Cir. 1990), affg. T.C. Memo.           
          1987-522).                                                                  
               In applying these factors, we note that petitioner’s                   
          education did not reflect a substantial background in tax or                
          financial matters.  Petitioner’s role in the family finances was            
          largely limited to paying the family expenses.  Petitioner                  
          received money to pay those expenses from Mr. Campbell, who                 
          deposited “$100,000 or so” from his trading profits every few               
          months.                                                                     
               Even though petitioner was the technical owner of the Refco            
          account that generated large profits in 1983, we find that she              
          was only a nominee and had no control over the funds in the                 
          account.  Petitioner’s only access to the account was from the              
          allowance she received from Mr. Campbell that he deposited in her           
          personal bank account.  Petitioner stated that she never asked              
          him to deposit any money.  Petitioner was aware that she received           
          a check issued to her in the amount of $1 million in 1982.  Part            
          of the $1 million was used to purchase the family home in                   
          Naperville, Illinois.  However, Mr. Campbell explained in his               
          testimony that he took the money out of petitioner’s account to             
          buy the home.  Petitioner had no involvement in Mr. Campbell’s              
          trading activities or in particular the London straddle.  Mr.               









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