Legal Opinion

Hall v. Comm'r

United States Tax Court

Decided May 15, 1989No. Docket No. 15095-86Published

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

Joseph E. Hall, Petitioner v. Commissioner of Internal Revenue, Respondent

Hall v. Comm'r

Docket No. 15095-86

United States Tax Court

92 T.C. 1027; 1989 U.S. Tax Ct. LEXIS 66; 92 T.C. No. 64;

May 15, 1989. May 15, 1989, Filed

Decision will be entered under Rule 155.

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.

W. Louis…

2Cases cited7 opinions

  1. Helvering v. RankinSupreme Court of the United States · 1935
  2. Davidson v. CommissionerSupreme Court of the United States · 1938
  3. Kluger Associates, Inc. v. CommissionerUnited States Tax Court · 1978
  4. Kluger Associates, Inc. v. CommissionerCourt of Appeals for the Second Circuit · 1980
  5. Joseph Gann, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1983

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