- 8 - was no taxable event as to such stock. Another contention by petitioner is that, of the amounts listed above, two of the stock sales listed, Harris Trust Co. in the amounts of $10,710 and $14,917, were incorrect and should have been, respectively, $4,310 and $5,967. Petitioner presented to the Court a Form 1099 from the Harris Trust Co. of New York that reflected a cash payment to petitioner of $5,967.50 during 1986; however, petitioner failed to prove that this Form 1099 related to any of the Harris Trust Co. transactions listed above. The Form 1099 for $5,967.50 presented by petitioner did not indicate that it was a corrected or amended Form 1099. Petitioner's position is not only vague but contradictory because, in support of her first argument, she acknowledged that the transactions at issue involving stock totaled $82,529 during 1986. To argue that two of the amounts making up the $82,529 are incorrect is simply contradictory to her acknowledgment that her stock transactions that year amounted to $82,529. On this record, petitioner has not satisfied her burden of proving that respondent's determination of her long-term capital gains for 1986 is incorrect. Respondent, therefore, is sustained on this issue. 3. Claimed Deduction for Expenses Relating to Rental Property The third issue is whether petitioner is entitled to a deduction for expenses incurred in connection with rental property during 1986 that was not allowed by respondent. In thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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