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1001(a) is recognized in the year of the sale with certain
exceptions not applicable in this case. Sec. 1001(c).
The amount realized from the sale is the sum of any money
received plus the fair market value of any property received.
Sec. 1001(b). In this case, the amount realized by petitioner
from the December 20, 1994, sale of Gillette common stock is
$6,114.79. In order to calculate the gain on the sale, we must
first determine petitioner's adjusted basis in the shares which
were sold on December 20, 1994.
Petitioner's adjusted basis in each share was $30.14.4
Although the precise number of shares that were sold on December
20, 1994, is not revealed in the record, petitioner testified
that the fair market value of the shares at the time they were
sold was approximately $75 per share. Based on her credible
testimony and the fact that the shares were sold only 1 week
after the distribution, at which time (i.e., the time of
distribution) the fair market value was $73.19 per share, we
accept her estimate of the fair market value of Gillette common
stock on December 20, 1994. After dividing the proceeds of the
sale ($6,114.79) by the fair market value of the stock
(approximately $75), we find that petitioner sold 82 shares on
December 20, 1994. Therefore, the adjusted basis in the 82
4 This amount is calculated by dividing petitioner's
aggregate basis in the Gillette common stock ($9,103.41) by the
total number of shares (302).
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