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sale. He was compensated with salary and stock options, which
options he exercised in early 2000.
Ms. Quinn was born in 1969 and graduated from the University
of Delaware in 1987 with a major in economics. She then went to
work for Lehman Brothers, Inc., in New York City. She was
employed as an institutional trader, executing at the
institutional desk trades of large blocks of stock for major
accounts. Mr. Arberg and Ms. Quinn met through her role as a
“sell side” trader and his as a “buy side” client of Lehman
Brothers, Inc., during his employment at Hemisphere Trading
Company. Ms. Quinn took a position as an institutional trader
with Salomon Smith Barney, Inc., in Atlanta, Georgia, in 1997 or
1998. Mr. Arberg and Ms. Quinn were married in Atlanta in May of
1998.
Mr. Arberg began buying and selling securities for his own
account in 1992, and he continued that activity through at least
2000. Petitioners testified that by 1998 Mr. Arberg had begun to
invest in extensive computer and telecommunications equipment and
access to specialized stock information services, such as those
referred to as the Bloomberg and InstaNet systems. Mr. Arberg
concentrated his activities in industry sectors with which he had
experience, particularly those involving telecommunications and
fiber optics. He described his strategy as follows:
A I would, without a doubt, consider myself a
position trader, where you’re taking the position
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