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took an income tax return preparation course at H & R Block at a
time not specified in the record.
B. Petitioner’s Stock Sales in 1998
1. Petitioner’s IBM Stock Transactions
a. Purchases of IBM Stock
Petitioner participated in the IBM Employees Stock Purchase
Plan (ESPP) from July 13, 1979, through August 31, 1995. He
typically bought shares of IBM stock each quarter at a price of
10-15 percent below the market price and withdrew the stock
certificates from the plan. Petitioner’s bases in certain shares
of IBM stock were as follows:
Stock certificate No. No. of shares Cost basis
479321 4 $214.22
711752 1 54.82
184316 1 71.09
331109 3 291.14
492586 3 290.87
687965 14 1,577.33
246717 11 1,421.24
674021 23 2,622.38
41127 38 4,605.45
370058 7 891.63
695343 50 4,939.29
529572 57 5,340.54
895652 65 5,975.89
431763 46 4,220.50
431764 1 91.75
Total 324 32,608.14
Petitioner also acquired 335 shares of IBM stock under an
IBM Investor Services Program (the program). Petitioner made
quarterly purchases of IBM stock under that program. From March
13, 1980, to January 27, 1992, he bought 46.541 shares of IBM
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