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respect to Kemper, he reported proceeds of $1,507, cost or other
basis of $1,288, and a resulting gain of $219. The parties’
disagreements over the amounts of petitioner’s gains result from
their disagreements over his costs of acquiring his interests in
Oxford and Kemper. The parties also disagree with respect to the
character of the gains and the availability of a loss carryover.
b. Petitioner’s Costs of Acquiring His Interests in
Oxford and Kemper
To determine gain realized on the sale of property, we must
subtract from the proceeds the taxpayer’s cost or other basis in
the property. See sec. 1001(a). Respondent proposes that we
find that petitioner had cost bases of zero in his interests in
both Oxford and Kemper, so that the gains he realized on the
sales of both equaled the proceeds received; viz, $3,406 and
$1,507, respectively. Respondent supports his proposed findings
of zero bases by directing us to a one-page joint exhibit, an
Internal Revenue Service (IRS) Form 1099-B, Proceeds from Broker
and Barter Exchange Transactions, which, among other things,
shows gross proceeds of $3,407 and $1,507 from sales of his
interests in Oxford and Kemper, respectively, but does not show
any cost or other basis for either asset. While petitioner has
made no objection to respondent’s proposed findings, he does
claim that brokerage statements showing costs and selling prices
for those assets were forwarded to respondent, and, in support of
that claim, he refers us to the Form 1099-B (which shows nothing
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