Christa Karin Mueller - Page 16




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          husband’s adjusted basis in his Omni shares, his amount realized,           
          and the amount and timing of any gain or loss.                              
                    3.  Adjusted Basis                                                
               Respondent has allowed petitioner no adjusted basis in                 
          husband’s Omni shares.  We have found that husband was indebted             
          to Omni in the principal amount of $844,635 for the purchase of             
          at least a portion of his shares in Omni.  We make that finding             
          based on a note, dated November 20, 1985, from husband to Omni,             
          which is an exhibit to the stipulation of facts agreed to by the            
          parties.  We have also found that, by the Form 8-K, A.T. Bliss &            
          Co., Inc. (Omni), reported husband’s purchase of 2,344,099 shares           
          during July 1985 for $421,614.85.  Those two purchases account              
          for most, but not all, of husband’s shares in Omni.  We find that           


               4(...continued)                                                        
                    In summary of the foregoing transactions,                         
               Petitioner’s husband Reinhard Mueller received the                     
               following proceeds as his liquidating dividend on the                  
               OMNI shares:                                                           
               DATE           ACTION           AMOUNT                                 
               May 1986:      Margin loan plus interest                               
                              offset by the broker WLJ Co.  $1,006,163                
               June 1987:     Settlement received from                                
                              Mr. Jacob personally for                                
                              defaulted debentures.         $100,000                  
               November 1987: Remaining claim under the                               
                              debentures exchanged for a                              
                              15% interest in a new                                   
                              company, which was then sold                            
                              in 1988 for                     $150,000                
               TOTAL proceeds from the OMNI dividend:      $1,256,163                 





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