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all Rule references are to the Tax Court Rules of Practice and
Procedure. All amounts have been rounded to the nearest dollar.
Background
All of the facts have been stipulated as to petitioner, and
these stipulated facts are incorporated in our findings by this
reference. Petitioners resided in Clay, West Virginia, at the
time that the petition was filed.
During the relevant period, petitioner was a licensed
physician in Clay County, West Virginia. During the years in
issue, petitioner also engaged in business as a “day trader” of
securities, buying and selling on his own account the same
securities on the same day or within a few days (trading
activity). Petitioner engaged in the trading activity for the
sole purpose of profiting from short-term fluctuations in the
market price of securities. Petitioner did not have any
customers for his trading activity, did not earn or attempt to
earn any commissions with regard to his trading activity, and did
not maintain a place of business for his trading activity.
Petitioner did not earn dividends or interest from the securities
in which he traded, and he did not engage in his trading activity
with the purpose of earning dividends or interest. Petitioner
was not, for Federal income tax purposes, a dealer in the
securities that he traded.
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Last modified: May 25, 2011