J. Randall and Jane B. Groves - Page 10




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                                        1989                                           
          # of        Date              Date   Sales              Cost or              
          shares       acquired     sold        price              basis               
          20,000         1/30/87     3/13/89    $240,000          $74,000              
          20,000         1/30/87     5/26/89     322,500      74,000                   
               Petitioner correctly listed the number of shares sold, the              
          date on which they were sold, and the sales price on the 1988                
          organizer.  However, he incorrectly listed acquisition dates.  He            
          also incorrectly listed the basis of the stock he sold in 1988               
          and 1989.                                                                    
               Petitioner did not give Delk documents to support the                   
          information he listed on the tax organizers.  Delk used the                  
          information from petitioner’s tax organizers to prepare                      
          petitioners' 1988 and 1989 tax returns.                                      
          D.   Petitioners’ Tax Returns for 1988 and 1989                              
               Petitioners reported on their 1988 and 1989 returns that                
          they sold OPCS stock as follows:                                             
                                        1988                                           
          # of shares    Reported       Sale            Gain      Actual               
          sold             Basis        price          reported    basis1              
          35,280         $158,760    $467,500        $308,740     $235                 
          3,000       13,000            52,500       39,500     20                     
          2,000         9,000           26,500          17,500    13                   
                                        1989                                           
          # of shares    Reported       Sale            Gain      Actual               
          sold              Basis        price         reported    basis1              
          20,000       $74,000          $240,000   $166,000       $133                 
          20,000          74,000        322,500      248,500  51,800                   
          1 This column was not on petitioners’ 1988 return.                           
               Petitioner received the 1988 return from Delk on April 14,              
          1989, and signed it without reviewing it in detail.                          





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