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capital losses of $147 and $640 on the respective sales of the
Daisy stock and the Gibraltar stock. At trial, petitioner
presented the Vanguard statements and the Vanguard 1099 for 1989,
the year in which the Daisy stock and the Gibraltar stock were
sold. Those documents show that at least during the last quarter
of 1987 to April 27, 1989, those stocks were held in an account
at Vanguard by Nathanael Roman as custodian for his son Matthew
Roman under the UGMA of New Mexico. The Social Security number
listed on the Vanguard statements and the Vanguard 1099 for the
Vanguard account was 525-53-6344. Petitioner's Social Security
number is 123-32-4215. The Vanguard 1099 indicated that on April
27, 1989, Nathanael Roman as custodian for Matthew Roman under
the UGMA of New Mexico sold the Daisy stock and the Gibraltar
stock. No evidence was offered at trial to contradict the
Vanguard statements and the Vanguard 1099, although we note that,
pursuant to the UGMA of New Mexico, petitioner should have
delivered the Daisy stock and the Gibraltar stock to his son when
he became 18 on December 3, 1987. See N.M. Stat. Ann. sec. 46-7-
4(D) (Michie 1978) (repealed July 1989).
Under New Mexico law in effect during all relevant times, "A
gift made in a manner prescribed in the Uniform Gifts to Minors
Act * * * is irrevocable and conveys to the minor indefeasibly
vested legal title to the security". N.M. Stat. Ann. sec. 46-7-
3(A) (Michie 1978) (repealed July 1989). A transfer under the
UGMA properly made under State law is effective to transfer the
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