Henry C. Boler and Sherry M. Boler - Page 15




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          in AIM’s books corroborate petitioner’s testimony.4  Scott was a            
          valuable employee of AIM who needed help.  Petitioner believed              
          Scott would repay the $14,900.  We conclude that the $14,900 AIM            
          paid to Scott was a loan.                                                   
               2.   Whether the $14,900 Debt Became Worthless in 1996                 
               To prevail, petitioners must identify some event or facts              
          which prove that the debt became worthless in 1996.  United                 
          States v. S.S. White Dental Manufacturing Co., 274 U.S. 398, 401            
          (1927); Dallmeyer v. Commissioner, 14 T.C. 1282, 1291-1292                  
          (1950).  Respondent contends that petitioners did not show that             
          the $14,900 debt became worthless in 1996.  We disagree.                    
               Disappearance of the debtor is a factor that can show that a           
          debt has become worthless.  Cole v. Commissioner, 871 F.2d 64, 67           
          (7th Cir. 1989), affg. T.C. Memo. 1987-228; Briant v.                       
          Commissioner, T.C. Memo. 1982-397; Acree v. Commissioner, T.C.              
          Memo. 1976-187.  Scott disappeared in 1996.  Petitioner tried               
          unsuccessfully to find him.  Further evidence that the debt                 
          became worthless in 1996 is that Scott told petitioner when Scott           





               4  Petitioner described the payments to Scott as “Loans to             
          shareholder” or “Accts. rec’ble - other” in AIM’s books.  The               
          four entries that state “Loans to shareholder” are at odds with             
          petitioners’ position.  However, the three entries that state               
          “Accts. rec’ble - other” are consistent with the contemporaneous            
          notations petitioner wrote on the checks and petitioner’s                   
          testimony that AIM lent money to Scott.                                     





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