Randon J. Scholet - Page 5

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               The following shares of IBM stock were transferred to                  
          petitioner’s Schwab account:                                                
                         Date                No. of shares                            
                         4/9/98                   324                                 
                         4/17/98                  133                                 
                         4/17/98                  26                                  
                         5/18/98                  335                                 
               Petitioner’s 324 shares of IBM stock transferred to his                
          Schwab account on April 9, 1998, were purchased through the ESPP.           
          His basis in those 324 shares was $32,608.14.  The record does              
          not indicate petitioner’s basis in the 159 shares (133 shares +             
          26 shares) of IBM stock transferred to his Schwab account on                
          April 17, 1998.  Petitioner’s 335 shares of IBM stock received by           
          his Schwab account on May l8, 1998, were those he had acquired              
          under the IBM investors program and for which he had a basis of             
          $6,133.78.                                                                  
                    b.   Sales of IBM Stock                                           
               Petitioner sold shares of IBM stock held in his Schwab                 
          account in 1997 and 1998 as follows:                                        
                Date          No. of shares            Proceeds                       
               11/4/97             100            $10,124.41                          
               4/21/98             300                 34,468.90                      
               7/21/98        1,000               128,340.77                          
               9/22/98             300                 38,781.25                      
               10/12/98            600                 78,042.44                      










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