Robert J. and Anne L. Wilson - Page 8

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          determined that petitioners had a $29,9041 unreported capital                
          gain.  However, respondent failed to give petitioners basis                  
          credit in determining their capital gain on the sale of the                  
          stock.  On brief, respondent conceded that petitioners had a                 
          basis in the stock fund of $29,214 and therefore are entitled to             
          a $2,009 loss on the sale of the stock.  Accordingly, respondent             
          should have subtracted $31,913 from her $29,904 of determined                
          unreported capital gain income.  This adjustment will account for            
          petitioners' $2,009 capital loss.  However, as discussed above,              
          respondent's Rule 155 computation erroneously decreases                      
          petitioners' capital gain by only $27,800.                                   
               Accordingly, we sustain petitioners' Rule 155 computation               
          for 1990.  However, with respect to the Rule 155 computation for             
          1989, the parties shall make the necessary adjustments as                    
          discussed herein.                                                            
               To reflect the foregoing,                                               
                                              An order will be issued                  
                                        for 1989 and 1990 directing the                
                                        parties to resubmit their Rule 155             
                                        computations in accordance with the            
                                        findings herein.                               




          1    We note that the record is unclear as to the source of the              
          additional $2,698 ($29,904 minus $27,206) of capital gain income.            




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