Richard A. and Carol B. Little - Page 36

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          record that the stock became worthless until August 19, 1988,               
          when the FHLBB placed Texana into receivership and appointed the            
          FSLIC to liquidate Texana.  Thus, if the year of worthlessness              
          were in issue, every indication from the record, although sparse,           
          is that the Texana Capital stock became worthless in 1988.                  
               2.   Basis                                                             
               Petitioners' basis in the Texana Capital stock is the amount           
          petitioner paid for it.  Sec. 1012.  The amount he paid includes            
          cash and other property given in exchange for the property and              
          any liabilities petitioner assumed or to which the property is              
          subject.  Commissioner v. Tufts, 461 U.S. 300, 307 (1983); Crane            
          v. Commissioner, 331 U.S. 1, 11 (1947).                                     
               Petitioner bought 34,900 shares of Texana Capital stock for            
          $199,600 on December 12, 1983.  Petitioner borrowed $77,200 for             
          the downpayment and executed notes for $106,795 and $15,605 to              
          buy the stock.                                                              
               Respondent contends that petitioners have not proven that              
          they had basis in the Texana Capital stock because they did                 
          not provide a copy of the $15,605 promissory note or other                  
          documentary evidence showing how much petitioner paid and that              
          petitioner's only evidence of payment is his testimony.  We may             
          not arbitrarily disregard testimony that is competent, relevant,            
          credible, and uncontradicted.  Conti v. Commissioner, 39 F.3d at            
          664.  We found petitioner's testimony to be generally credible.             






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