- 5 - From this we distill the following. First, prior to March 8, 1996, petitioner owned 100 shares of IBM stock, as evidenced by the fact that he received the March 11, 1996, dividend. Second, during 1996, petitioner purchased and sold 200 shares of IBM stock. He, therefore, still owned the same number of shares that he owned prior to March 11, 1996. Third, during January 1997, petitioner purchased 100 shares and sold 100 shares of presplit stock. During 1997, petitioner purchased 900 shares and sold 800 shares as follows: Transaction Balance of Shares 1997 Opening Balance IBM Shares 100 Sell 1/23 100 15,374 -0- Buy 1/28 100 15,287 100 Sell 5/16 100 15,424 -0- May 27, 1997 - 2:1 Stock Split Sell 9/19 600 59,923 (600) Buy 9/26 200 20,500 (400) Buy 10/28 400 38,975 -0- Buy 10/29 200 20,237 200 The cost of shares is petitioner’s basis for determining a gain or loss on the transaction. See secs. 1011, 1012, 1016. In attempting to identify which shares were sold, and in the absence of other identification, we use the first-in first-out method of accounting. Kluger Associates, Inc. v. Commissioner, 617 F.2d 323, 326-327 (2d Cir. 1980), affg. 69 T.C. 925 (1978); sec. 1.1012-1(c)(1), Income Tax Regs. With regard to the sale on January 23, 1997, this stock was purchased on March 11, 1996, forPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011