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from that account to open a brokerage account. On January 16,
1987, Mr. Del Bosque purchased 234 shares of Fidelity Growth Fund
for $3,320. On April 22, 1987, he sold those shares for $3,756
and purchased 1 share for $16. Mr. Del Bosque reported the $436
gain from the sale of the 234 shares on his 1987 return. On
January 22, 1988, he sold the remaining share for $13. On his
1988 return, he erroneously reported a basis of $3,320 in the 1
share and a $3,307 long-term capital loss on the sale of the
share.
At the end of 1987, Mr. Del Bosque owed $3,921 to Larson
Quinn Motor Co. He repaid the loan in 1988.
During the years at issue, petitioners purchased leather
goods (mostly leather jackets) for resale. In both 1987 and
1988, Mr. Jacobsen purchased $3,770 of leather goods for resale.
Mr. Del Bosque purchased $13,298 of leather goods for resale in
1987, $3,862 for resale in 1988, and $2,375 for resale in 1989.
Petitioners did not keep any records of their sales of leather
goods.
During the years at issue, petitioners each owned 50 percent
of the stock of Top Play, Inc. (Top Play), an S corporation doing
business as Twin Star Limousine Service.
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