Stanley C. Cameron - Page 9




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          purchases and 30 sales in the second year.  Moller v. United                
          States, supra at 813.                                                       
               In 2002, petitioner’s trading activity consisted of 46                 
          purchases and 14 sales.  In 2003, he completed 109 purchases and            
          103 sales.  During the years at issue, petitioner did not trade 5           
          days a week.  Of the years at issue, he traded on more than 10              
          days in a given month only twice.  We also note that petitioner’s           
          collecting unemployment compensation during 2003 further                    
          undermines his argument that he was engaged in a trade or                   
          business during that year.  We conclude that petitioner was not             
          engaged in a trade or business of trading securities during the             
          years at issue and thus that his expenses related to his trading            
          activities are not deductible under section 162.  We also agree             
          with respondent’s determination that none of the expenses, but              
          for the $200 and $28 expenses allowed in the notice of                      
          deficiency, are deductible by petitioner under section 212, in              
          that petitioner has failed to demonstrate that the expenses were            
          incurred for the production of income.  We also note in this                
          regard the applicability of section 274(h)(7), which disallows              
          any deduction under section 212 for expenses allocable to a                 
          convention, seminar, or similar meeting.                                    












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