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2001, Klever notified Atlas that petitioner had recently asked it
to lift the restrictive legend as to the shares underlying
certificate number 6278 and to transfer those shares into the
street name of Prudential. On November 28, 2001, in response to
this notification, Atlas cancelled certificate number 6278 and
issued in the street name of Prudential certificate number 6980
with no restrictive legend. Street name securities are held by a
company such as Prudential for the benefit of its clients.
Securities held in street name may be placed into an individual’s
account and beneficially owned by the individual although the
owner listed in the transfer agent’s records is a street name. A
transfer agent usually does not know the identity of the owner of
securities which are recorded in its records in street name.
OPINION
Respondent determined that petitioner received a $461,709
distribution during 2000. Respondent in support of that
determination focuses on the fact that petitioner, during 2000,
both authorized the distribution and received it in her account.
Petitioner argues that she received no distribution during 2000.
Petitioner focuses on the fact that certificate number 6278 was
not changed during 2000 to reflect any change in the name of the
underlying shares’ owner and that this certificate contained a
legend that prohibited any transfer of the underlying shares
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Last modified: May 25, 2011