- 16 -
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
Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: May 25, 2011