J. Randall and Jane B. Groves - Page 9




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          in 1988 that he intended to sell only shares he had acquired from            
          OPCS (or its predecessor).                                                   
               7.   Petitioner’s Gift of Stock in 1989                                 
               On May 5, 1989, petitioner gave 20,000 shares of One Price              
          stock to Campus Crusade for Christ.  He told Campus Crusade for              
          Christ that petitioners’ tax considerations would determine when             
          he made further contributions to that organization.                          
          C.   Preparation of Petitioners' Income Tax Returns for 1988 and             
               1989                                                                    
               Petitioner prepared tax organizers for 1988 and 1989 and                
          gave them to Delk.  Petitioner used Forms 1099 and W-2 to                    
          complete the tax organizers for 1988 and 1989.  Petitioner did               
          not have a schedule or records showing his basis in, or number of            
          shares of, OPCS stock when he listed the bases of the stock                  
          petitioners sold in 1988 and 1989 on the tax organizers.  There              
          is no indication that petitioner knew the basis in his OPCS stock            
          in 1988 or 1989.  Petitioner listed the following information                
          about the stock he sold in 1988 and 1989 in the tax organizer for            
          1988 and 1989:                                                               
                                       1988                                            
          # of         Date       Date     Gross sales     Cost or                     
          shares       acquired     sold        price      other basis                 
          35,280         1/30/87      5/3/88    $467,500      $158,760                 
          3,000          2/1/87     3/15/88          52,500        13,000              
          2,000          2/2/87     5/15/88          26,500         9,000              










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