- 5 - Singer issued to Mr. Clopton a Form 1099-B, Proceeds From Broker and Barter Exchange Transactions, for 1999. The Form 1099-B showed proceeds from the sale of “Stocks, bonds, etc.” of $1,155,000.10. Petitioners jointly filed a Form 1040, U.S. Individual Income Tax Return, for 1999. On Schedule D, Capital Gains and Losses, petitioners reported the assignment of the 20 future annual payments of $120,000 to Singer as a sale of a capital asset held more than 1 year. Petitioners reported a sales price of $1,155,000, a cost or other basis of $10,334,2 and a long-term capital gain of $1,144,666. On December 24, 2002, respondent issued a notice of deficiency to petitioners for the year 1999. In the notice, respondent determined that the $1,155,000 received from Singer was ordinary income. Respondent determined that the cost or other basis reported on petitioners’ return with respect to the amount received from Singer was zero. Petitioners reported on their joint return for 1999 a short- term capital loss of $9,088 on Schedule D, Capital Gains and Losses, for unrelated transactions. Due to a scrivener’s error, 2The record does not reflect how petitioners computed the cost or other basis amount of $10,334. Petitioners have not argued or elaborated on brief with respect to this point, nor have they argued that if we find for respondent then this basis amount must be considered in calculating the amount of ordinary income resulting from the sale to Singer.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011