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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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