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death on or about May 28, 1993, and, two, the transfer of the
securities on account of her death. Death is not exclusively a
private event. It is usually accompanied by public recognition,
in the form of a death certificate and, sometimes, court records
evidencing the administration or probate of the decedent’s
estate. Often there is a will, and there are newspaper articles
reporting the decedent’s death. There is a substantial amount of
money involved here, and the lack of any evidence supporting
petitioner’s wife’s testimony on crucial points causes us to
distrust that testimony as to the fact or date of the
grandmother’s death. With respect to the fact of the transfer of
the securities, stock transfers (especially of the stock of
traded companies) are evidenced by record entries. The
securities in question here were sold by Smith Barney, who, we
assume, would not have sold them and deposited the proceeds to
petitioner’s account unless Smith Barney was satisfied petitioner
owned the securities. Petitioner produced no evidence of the
transfer of any of the securities from his grandmother to him.
We cannot, therefore, conclude that petitioner acquired
securities from his grandmother or that, even if he did, he
acquired them on or about May 28, 1993. We have similar
difficulty with the petitioner’s wife’s testimony about the gift
of the Honeywell shares.
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