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worth $2,541. On his 2003 Schedule D, he reported 65 sales
totaling $88,799. He also reported on Form 6781, Gains and
Losses from Section 1256 Contracts and Straddles, losses from
futures transactions as a loss from section 12562 contracts
marked to market. Petitioner held 30 futures contracts for 1 to
30 days. He held 21 futures contracts for 31 to 60 days. He
held seven futures contracts for 60 to 90 days. He held seven
futures contracts for 91 to 180 days. Petitioner’s 2003 Schedule
C for Cameron Enterprises reported that its “principal business
or profession” was “SERVICE MARKET TRADI”. The Schedule C
reported no income from the business and expenses totaling
$8,797. The expenses consisted of $959 for travel, $6,043 for
continuing education, and $1,795 for “ongoing services”. Also in
2003, petitioner reported receiving unemployment compensation of
$11,971.
During the years at issue, petitioner did not conduct trades
5 days a week. Of the years at issue, there were only 2 months
in which petitioner conducted trading activity on more than 10
days. On the days he was not conducting trades, petitioner was
maintaining a cash position.
Petitioner’s continuing education expenses for 2002 and 2003
were attributable to his attending seminars related to his
2 Unless otherwise indicated, section references are to the
Internal Revenue Code, and Rule references are to the Tax Court
Rules of Practice and Procedure.
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Last modified: November 10, 2007