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600 shares. We note that on May 27, 1997, IBM stock was split 2
for 1.
The tax statement for 1996 shows that petitioner sold 100
shares of IBM stock for $11,249.62 on March 8, 1996, purchased
200 shares of IBM stock for $23,275 on March 11, 1996, and had
received a dividend from IBM of $25 on March 11, 1996. The
receipt of this dividend indicates that he must have owned IBM
stock prior to the sale on March 8, 1996, because the
distribution record date had to have been prior to that date.
Furthermore, the quarterly dividend rate for IBM at that time was
$.25 per share, indicating that petitioner owned 100 shares. The
1996 statement also shows that petitioner sold 100 shares on
December 30, 1996. Thus, at the end of 1996, petitioner owned
100 presplit shares of IBM stock purchased for $11,637.50
($23,275 divided by 2) on March 11, 1996.
During 1997, the statement for that year shows that
petitioner purchased: 100 presplit shares of IBM stock for
$15,287.50 on January 28, 1997, 200 postsplit shares of IBM stock
for $20,550 on September 26, 1997, 400 postsplit shares of IBM
stock for $38,975 on October 28, 1997, and 200 postsplit shares
of IBM stock for $20,237.50 on October 29, 1997. That statement
also shows that he sold 100 presplit shares on January 23, 1997,
100 presplit shares on May 16, 1997, and the 600 postsplit shares
on September 19, 1997.
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