On December 30, 2020, Taxpayer T ("T") received 100 shares of X Corporation stock from T's employer as compensation for services provided.
As of that date. each X share had a fair market value ("FMV") of $1.000 (i.e.
$100.000 value in total). On December 30. 2021. each X share had a FMV of $1,100 per share. On December 30, 2022, When each X share had a FMV of $950 per share. T gifted 50 X shares to T's son ("S"). S combined the 100 shares in a single account and could not distinguish which shares S received on any given date. On December 30.
2023, when each X share had a FMV of $1,200 T gifted the remaining 50 shares to S.
a. What income, gain or loss. if anv, would S recognize if S sold all 100 shares of X stock for $150,000 on January 1, 2024?