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securities by comparing the sales price of each security with its
tax basis, as he computes those bases. With one exception, i.e.,
shares of stock in Honeywell Intl. Inc. (the Honeywell shares),
he computes the tax basis of each of his various security
holdings as being the fair market value of the security on May
28, 1993, the date he claims is the date of his grandmother’s
death.
Petitioner’s wife testified that, to the best of her
recollection, petitioner’s grandmother died on May 28, 1993. She
testified that, except for the Honeywell shares, all of the
securities were received by petitioner on account of his
grandmother’s death. She testified that the Honeywell shares
were a gift to petitioner from his mother. Petitioner did not
testify to those matters. There is in evidence a letter from
Smith Barney that, for some of the securities, states prices for
the securities on May 28, 1993.
Section 1001(a) deals with the computation of gain or loss
on the sale or other disposition (without distinction, sale) of
property. Gain is the excess of the amount realized on the sale
of property over the property’s adjusted basis (basis) for
determining gain. Id. Loss is the excess of the property’s
basis for determining loss over the amount realized on its sale.
Id. The basis of property may be different for purposes of
determining whether property is sold at a gain or whether it is
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