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During 1990, petitioners sold 13,1502 shares of Price Co.
stock for $482,903, triggering recognition of capital gain.
Petitioners claimed a total basis of $197,455 for those shares on
Schedule D of their 1990 Federal income tax return. Petitioners
claimed a stepped-up fair market value basis in only the shares
transferred to them by Drachman on October 30 and December 10,
1987, and acknowledged that the preceding shares of Price Co.
stock were acquired by gift. Additionally, petitioners claimed
$37,545 in deductible investment interest on Schedule A and Form
4952 of their 1990 Federal income tax return. Of this $37,545,
petitioners claimed $22,800 as investment interest paid to
Drachman for the Price Co. stock transferred to petitioners on
October 30 and December 10, 1987.
On April 15, 1991, petitioners filed a Form 4868 Application
for Automatic Extension of Time to File U.S. Individual Income
Tax Return for their 1990 Federal income tax return, on which
they claimed their tax liability to be zero. On August 13, 1991,
petitioners filed a Form 2688 Application for Additional
Extension of Time to File U.S. Individual Income Tax Return for
their 1990 Federal income tax return, requesting an extension of
2 The parties stipulated that petitioners sold 13,350
shares of Price Co. stock during 1990. We note, however, that
the Form 1099 for petitioners' account indicates, and respondent
argued on brief that, 13,150 shares of Price Co. stock were sold.
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