John Edward and Linda Hall - Page 2

                                          2                                           
          the Tax Court Rules of Practice and Procedure, except as                    
          otherwise noted.                                                            
               Petitioners, John Edward and Linda Hall, were residents of             
          Kansas at the time the petition was filed herein.  Hereinafter,             
          all references to "petitioner" refer to John Edward Hall.                   
               In the year 1986, a corporation known as Hall/McCollum                 
          Laboratories, Inc., was formed in the State of Nevada.  One                 
          million shares of this corporation were issued to petitioner.  In           
          1987, petitioner sold back to the corporation 800,000 of these              
          shares, for which he received $150,000.                                     
               Thereafter, a dispute arose between petitioner and the                 
          corporation and, after the corporation had changed its name to              
          HML Medical, Inc., petitioner brought suit against it.  In 1990,            
          the dispute was settled, and the lawsuit was dismissed.  As part            
          of the settlement, petitioner surrendered his remaining 200,000             
          shares of the corporation to it, in return for the payment to him           
          of $212,500.                                                                
               Upon audit, respondent determined that petitioner's                    
          remaining cost basis in his stock in the corporation was only               
          $8,801, as compared to a basis of $212,500, which petitioner had            
          claimed in his return.  Respondent also disallowed a claimed net            
          capital loss carryforward of $3,000 contained in petitioner's               
          return.  Finally, respondent, having initially allowed a net                
          operating loss carryback to petitioner from 1991 to 1990 in the             






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