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2. Long-Term Capital Gain
The second issue is whether long-term capital gain realized
by petitioner in 1986 is less than the amount determined by
respondent. On her 1986 Federal income tax return, petitioner
did not report any gain or loss from the sale of capital assets.5
During the examination of petitioner's 1986 tax year, respondent
determined, based upon information furnished by payers, that
petitioner sold stock during 1986 totaling $82,529 as follows:
RCA Corp. $ 6,650
Financial Clearing & Services 7,010
Financial Clearing & Services 1,377
Burroughs 17,136
Harris Trust Co. 10,710
Harris Trust Co. 14,917
Duke Power Co. 2,575
Merrill Lynch 2,569
Merrill Lynch 257
Merrill Lynch 7,063
Polaroid Corp. 25
Burroughs 12,240
Total $82,529
In the examination of her 1986 tax year, petitioner provided
information to respondent's auditing agent that showed that she
had a basis of $65,071 in the stock listed above. Respondent's
agent accepted this amount as petitioner's basis and,
accordingly, determined that petitioner realized a long-term
4(...continued)
exemption. See sec. 152(e).
5
Petitioner's 1986 return did not include a Schedule D,
Capital Gains and Losses.
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