- 3 - on line 29 of Schedule C, Profit or Loss From Business, of his Forms 1040, U.S. Individual Income Tax Return, for taxable years 1999 and 2000, respectively. During the fall of 1999, petitioner decided to begin a new career as a securities trader. Petitioner established brokerage accounts with DLJdirect and Ameritrade, deposited $5 million in each of those accounts, and became engaged in the trade or business of trading securities on January 28, 2000.1 Petitioner used margin borrowing as part of his securities trading strategy. On April 14, 2000, DLJdirect forced the liquidation of petitioner’s entire account because petitioner failed to cover a margin call after technology stocks declined sharply during early April 2000. As of April 14, 2000, petitioner’s net trading losses totaled $25,196,151.54. Petitioner relied on certified public accountants to advise him on Federal tax matters and to prepare his Federal tax returns. J. Wray Pearce (Mr. Pearce), a certified public accountant with over 30 years of experience, had served as petitioner’s business and personal accountant for more than 13 years and was very familiar with petitioner’s securities trading business. 1The parties stipulated this fact based on the volume and frequency of petitioner’s trading.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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