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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,
1994.
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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