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During 1986, Mr. Sparrow maintained a stock account at
Anderson Bryant & Co. (Anderson Bryant). Mr. Sparrow received a
$9,998 check from Anderson Bryant, dated August 1, 1986, which
was payable to “Robert D. Sparrow”. Petitioners did not include
this $9,998 in their 1986 gross income.
During 1986, the brokerage firm of Wilson-Davis & Co.
(Wilson-Davis), purchased and sold stock for petitioners. On
August 12, 1986, Wilson-Davis sold 40,000 shares of NRG on behalf
of petitioners for $11,284, and purchased 1,300 shares of
Centurion stock on behalf of Mr. Sparrow for $985. The cost of
the purchase was deducted from the proceeds from the sale, and
Mr. Sparrow received a $10,299 check from Wilson-Davis, dated
August 19, 1986. Petitioners did not include the $11,284 in
their 1986 gross income.
On August 25, 1986, Wilson-Davis sold 40,000 shares of NRG
on behalf of Mr. Sparrow for $7,020. On August 26, 1986,
Mr. Sparrow purchased 1,000 shares of Centurion for $665, which
amount was deducted from the proceeds of the prior day’s sale.
Mr. Sparrow received a $6,354 check from Wilson-Davis dated
August 29, 1986. Petitioners did not include this $7,020 in
their 1986 gross income.
On September 18, 1986, Wilson-Davis sold 10,000 shares of
National Division stock on behalf of Mr. Sparrow for $557.
Mr. Sparrow received a $557 check from Wilson-Davis dated
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