Randon J. Scholet - Page 4

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          stock through the program for a total cost of $5,130.94.  On                
          January 27, 1992, petitioner sold .541 shares of IBM stock held             
          through the program.                                                        
               On May 27, 1997, the IBM stock in the program split, and 46            
          shares of petitioner’s IBM stock became 325 shares.  Petitioner             
          bought an additional 10.895 shares through the program for a                
          total cost of $1,090.43.  After selling .895 shares, petitioner             
          had 335 shares of IBM stock (represented by stock certificate No.           
          156716) for which he had a basis of $6,133.78 ($6,221.37 paid               
          minus $87.59 basis in the .541 and .895 shares sold).                       
               Petitioner maintained an investment account at Charles                 
          Schwab & Co. (Schwab account).  On August 1, 1997, petitioner               
          held 110 shares of IBM stock in that account.  Petitioner’s basis           
          in those shares is not in the record.                                       
               Petitioner bought IBM stock in 1997 and 1998 as follows:               
                     Date       No. of shares      Total price                        
                    9/11/97         1.2275             $22.00                         
                    10/28/97     100              8,944.00                            
                    12/10/97        1.2145             22.05                          
                    1/12/98   100                 9,831.50                            
                    1/12/98   100                 9,844.00                            
                    2/xx/98   100                 10,229.95                           
                    3/11/98         1.6311             62.09                          
                    6/11/98        11.1112             130.70                         
                    6/11/98   500                 58,529.95                           
                    6/16/98   500                 55,967.45                           
                    9/11/98        11.6355        204.64                              
               1 Petitioner acquired these shares with reinvested                     
          dividends.                                                                  







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