FGH, Inc.issued stock to individuals for $800,000 cash in 1980 and $400,000 in 1987.None of the stock currently qualifies as § 1244 stock since the paid-in capital of the corporation exceeds $1,000,000.

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Section 1244 of the Internal Revenue Code allows for the treatment of losses on small business stock as ordinary losses rather than capital losses, subject to certain conditions. The $1,000,000 limit refers to the aggregate amount of money and other property contributed to the corporation in exchange for stock that qualifies for § 1244 treatment. The issuance years and amounts do not automatically disqualify the stock from being § 1244 stock; other factors such as the type of business and how the capital was used also play a role.

FGH, Incissued Stock to Individuals for $800,000 Cash in 1980 and and $400,000