- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011