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For the years in issue, petitioner reported income and basis
and claimed losses with regard to his trading activity on
Schedules C, Profit or Loss From Business, identifying his
profession as “Stock Day Trader” in 2000, “Trader” in 2001, and
“Day Trader” in 2002. The number of transactions, gross
receipts, total basis, and losses with respect to petitioner’s
trading activity for each of the years in issue were as follows:
No. of Gross Direct Total
Year Trans. Receipts Total Basis Losses Losses
2000 118 $14,487,667 $16,409,654 $1,921,987 $1,978,747
2001 81 655,764 993,906 338,142 377,388
2002 53 1,788,341 2,040,663 252,322 252,322
The total losses indicated above include allowable interest
expenses claimed by petitioner in the amounts of $56,760 for 2000
and $39,246 for 2001. On his returns for the years in issue,
petitioner did not elect to use a “mark to market” method of
accounting for his trading activity. Petitioner reported income
and expenses associated with his medical practice, identifying
his profession as “Physician” in all years, on Schedules C
separate from those reporting his trading activity.
From losses sustained in his trading activity, petitioner
claimed net operating loss (NOL) carryovers in the amounts of
$545,907 in 2001 and $2,027,136 in 2002. He used the claimed NOL
carryovers to offset his reported net income from his medical
practice in those years.
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Last modified: May 25, 2011