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was opened to the date it was closed during 1997. Petitioner
offered one statement from GE on the account dated October 27,
1995, for the period October 26, 1994, to October 25, 1995. That
statement shows that, at the beginning of the period, petitioner
had a balance of 56.6504 shares in GE. Between that date and the
ending date for that statement (October 25, 1995), there were 12
transactions in the account in which dividends were paid and used
to purchase fractional shares of GE, and cash payments were made
to the account by petitioner, which were also used to purchase
fractional shares in GE. The statement shows the cost of the
stock for each of these transactions but does not state the cost
of the 56.6504 shares that were in the account at the beginning
date of the statement, nor the cost of the 64.2886 shares held in
the account on October 25, 1995.
Of the 12 transactions listed on the statement of the
account offered into evidence, petitioner highlighted 9
transactions on that statement that he contends constituted the
cost or basis for the 13.3048 shares he converted into cash when
he closed the account with GE on May 19, 1997.2
Under section 1001(a), gain from the sale or other
2 Sometime after the date of the statement, GE declared a
two for one stock split. The 13.3048 shares petitioner converted
into cash during 1997 represented stock for which petitioner had
received the benefit of the split. Therefore, in determining
petitioner's basis in the transaction at issue, the Court, in
relying on the account statement described, adjusted for the
effect of the split.
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