- 16 - husband’s adjusted basis in his Omni shares, his amount realized, and the amount and timing of any gain or loss. 3. Adjusted Basis Respondent has allowed petitioner no adjusted basis in husband’s Omni shares. We have found that husband was indebted to Omni in the principal amount of $844,635 for the purchase of at least a portion of his shares in Omni. We make that finding based on a note, dated November 20, 1985, from husband to Omni, which is an exhibit to the stipulation of facts agreed to by the parties. We have also found that, by the Form 8-K, A.T. Bliss & Co., Inc. (Omni), reported husband’s purchase of 2,344,099 shares during July 1985 for $421,614.85. Those two purchases account for most, but not all, of husband’s shares in Omni. We find that 4(...continued) In summary of the foregoing transactions, Petitioner’s husband Reinhard Mueller received the following proceeds as his liquidating dividend on the OMNI shares: DATE ACTION AMOUNT May 1986: Margin loan plus interest offset by the broker WLJ Co. $1,006,163 June 1987: Settlement received from Mr. Jacob personally for defaulted debentures. $100,000 November 1987: Remaining claim under the debentures exchanged for a 15% interest in a new company, which was then sold in 1988 for $150,000 TOTAL proceeds from the OMNI dividend: $1,256,163Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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