Sigitas Banaitis v. Commissioner of Internal Revenue

OPINION

THOMAS, Circuit Judge.

Sigitas Banaitis appeals the United States Tax Court’s entry of judgment in favor of the Commissioner of Internal Rev enue regarding a $1,708,216 deficiency in Banaitis’ 1996 income tax. We affirm in part and reverse in part.

I

From 1980 until late 1987, Sigitas Banai-tis, an Oregon resident, worked as a vice president and loan officer with the Bank of California. On behalf of the Bank of California, Banaitis developed grain-focused finance activity in Portland, Oregon, then the largest grain exporting port on the west coast. Banaitis had access to private…