Howard v. More v. Commissioner

115 T.C. No. 9

UNITED STATES TAX COURT HOWARD V. MORE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4455-99. Filed August 15, 2000. P is an individual underwriter for Lloyd’s of London (Lloyd’s). As an underwriter, P is required to demonstrate that he can cover potential losses on the policies that he underwrites, a.k.a., show means. In order to show means, P posted a letter of credit issued by Bank Julius Baer (BJB) with Lloyd’s. The letter of credit was secured by P’s preexisting stock portfolio. The policies that P underwrote for the taxable years 1992 and 1993…