Roger Steven Lewis - Page 4

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          the amount of money available at any given time was not                     
          sufficient to buy whole shares.  No stock certificates were                 
          issued to petitioner; however, GE regularly issued statements of            
          the account reflecting contributions and dividends credited to              
          the account along with the number of GE shares held.  The record            
          is not clear as to the date petitioner opened this account,                 
          except that the account was opened sometime prior to October 26,            
               On May 19, 1997, petitioner closed the account and elected             
          to receive a stock certificate for 100 shares of GE.  The                   
          remaining 13.3048 fractional shares were converted by petitioner            
          into cash, for which he received $802.94 from GE.  A Form 1099B,            
          Proceeds From Broker Transactions, was issued by GE to petitioner           
          in early 1998 reflecting this transaction in 1997.  No Federal              
          income tax was withheld by GE on this transaction.                          
               The parties agree as to the amount realized, $802.94, and              
          further agree that the conversion of the 13.3048 fractional                 
          shares was a taxable event.  The parties disagree on the amount             
          of petitioner's basis.  Respondent, at trial, agreed that                   
          petitioner had some basis for the fractional shares in GE but               
          declined to make a determination of an amount.  Petitioner                  
          contends his basis for the fractional shares was $364.87.                   
               Petitioner did not have a complete record of all the                   
          statements issued by GE on the account from the date the account            

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