Hall v. Comm'r
United States Tax Court
Petitioner failed to adequately identify which shares of uncertificated mutual fund stocks he sold. Respondent correctly applied the FIFO method of accounting, as provided in sec. 1.1012-1(c), Income Tax Regs., in determining petitioner's basis in the stock he sold for purposes of determining petitioner's gains and losses.
1Opinion of the Court
Drennen, Judge:
Respondent, in a statutory notice of deficiency dated March 11, 1986, determined a deficiency in petitioner’s Federal income tax in the amount of $33,149.
The issues for consideration are: (1) Whether petitioner correctly computed gain and loss on 1982 sales of Kemper Technology Fund, Inc. (Technology) noncertificate stock; and (2) whether petitioner correctly computed gain and loss on 1982 sales of Kemper Summit Fund, Inc. (Summit) noncertificate stock.
FINDINGS OF FACT
This case was submitted fully stipulated pursuant to Rule 122.1 The stipulation of facts, together with the…
2Cases cited6 opinions
- Helvering v. RankinSupreme Court of the United States · 1935
- Davidson v. CommissionerSupreme Court of the United States · 1938
- Kluger Associates, Inc. v. CommissionerUnited States Tax Court · 1978
- Kluger Associates, Inc. v. CommissionerCourt of Appeals for the Second Circuit · 1980
- Joseph Gann, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1983
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3Cited by3 opinions
- Rendall v. CommissionerCourt of Appeals for the Tenth Circuit · 2008
- Concord Instruments Corp. v. CommissionerUnited States Tax Court · 1994
- Hall v. Comm'rUnited States Tax Court · 1989