Chris E. Columbus - Page 11

                                       - 11 -                                         

                  Based on information available to us, you had                       
                  stock sales in the amount shown below.  If you                      
                  can substantiate this is not all taxable income,                    
                  and verify your basis in the stock sold, we will                    
                  be glad to reconsider this adjustment.                              

                  Petitioner contends that he did not realize any gain                
             from the sales of his employer's stock during any of the                 
             years in issue.  At trial, petitioner testified that he                  
             participated in an employee stock purchase plan under which              
             $100 per month was deducted from his wages and used to                   
             purchase his employer's stock.  Petitioner's testimony is                
             corroborated by an employee stock purchase plan quarterly                
             statement issued by Merrill Lynch for the last quarter of                
             1992 and by a pay statement issued by American Airlines,                 
             Inc., for August 14, 1992, and December 15, 1994.  We                    
             accept petitioner's testimony that the cost of purchasing                
             the stock that he sold during each of the years in issue                 
             was equal to or greater than the amount he realized from                 
             the sale of stock and that he did not realize a gain from                
             the sales during any of the years in issue.                              
                  Fourth, petitioner claims to be entitled to collect                 
             "damages" of $17,732.46 from the Internal Revenue Service                
             on the ground that "no one should ever profit from improper              
             acts, be it an individual, or governmental agent."  He                   







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011