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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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