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Date Amount Shares Sold
Jan. 28 $79,914.32 10,200 Fed. Natl. Mtg.
Feb. 1 195,071.36 7,600 Marion Labs
Feb. 9 60,979.35 2,400 Marion Labs
Feb. 12 54,798.16 5,000 Lorimar Telepi
Feb. 18 256,692.50 10,000 Intel
Feb. 22 105,246.38 25,000 Navistar Intl.
Total 752,702.07
On April 4, 1988, petitioner transferred a $4,500 dividend paid
on the Kodak stock in the FCIS account from that account back to
Albank No. 1. On his 1988 return, petitioner reported the gains
and losses on all of the foregoing sales except with respect to
the Federal National Mortgage Association (Fed. Natl. Mtg.)
stock.
As noted, the Kodak stock and Pan Am stock were not
liquidated and transferred back to Albank No. 1; instead, each
was subsequently transferred from petitioner’s FCIS account to
other personal accounts of petitioner’s.
The Kodak stock was transferred from petitioner’s FCIS
account on March 4, 1988 (3 days after Northwest began an audit
of petitioner’s corporations’ consolidator activities, see infra
p. 22), to account No. 03T 112101 at Prudential-Bache (P-B No.
1), another personal account. The Pan Am stock remained in the
FCIS account until April 11, 1988, when it was transferred to P-B
No. 2, another personal account. Petitioner’s FCIS account was
then closed.
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