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Commissioner, 87 T.C. 74, 77 (1986); see Jackson v. Commissioner,
19 T.C. 133, 145 (1952), affd. 207 F.2d 857 (10th Cir. 1953).
Under the circumstances of the instant case, we are not required
to, and we generally do not, rely on petitioner's testimony to
sustain petitioners' burden of proving error in respondent's
determinations. See Geiger v. Commissioner, 440 F.2d 688, 689-
690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159; Wood
v. Commissioner, supra; Tokarski v. Commissioner, supra.
Consequently, we conclude that petitioners have not established
that the alleged advances in the amount of $7,020 to two or three
individuals constitute bona fide debt that is deductible as a
business bad debt.
As to the bad debt deduction claimed by petitioners for the
alleged worthlessness of capital stock in Annabelle's restaurant,
petitioners conceded that they paid $3,000 to Annabelle's "for
its capital stock." Petitioners, however, argue that petitioner
purchased the stock with the understanding that he would perform
the restaurant's legal work. Petitioners provided two checks
drawn on petitioner's account that were written to "Annabelle's",
one in the amount of $150 and a second in the amount of $2,000.
A deduction for a bad debt is limited to a bona fide debt,
that is, debts that arise from a debtor-creditor relationship
based upon a valid and enforceable obligation to pay a fixed or
determinable sum of money. Sec. 1.166-1(c), Income Tax Regs.
Petitioners did not argue, and have failed to establish, that the
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