The appellate court said that Hawkins sold "various quantities of UBS stock" and claimed losses connected to that stock of "approximately $6 million on his 1996 federal tax return, $23.4 million on his 1997 return, $20.5 million on his 1998 return, $3.5 million on his 1999 return, and $8.2 million on his 2000 return.