Oliver Q. Foust and Talietha Foust - Page 6

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            petitioner and contains the notation "V.B.H. Investment".  In the                              
            year-to-date general ledger (ledger) for GSCH for the period                                   
            ended November 30, 1985, an asset account is shown under account                               
            number 205 and is titled "Investment-Vosburg Hotels Inc."                                      
            Moreover, on the Schedule L of GSCH's corporate tax return, there                              
            is an entry listed as an "investment" in the amount of $25,000.                                
            From these records, one would logically conclude that the $25,000                              
            represents GSCH's investment in Vosburg, rather than petitioners'                              
            investment.                                                                                    
                  Petitioners also rely on checks drawn on bank accounts at                                
            Bank of America and Wells Fargo Bank, which they referred to as                                
            the "Entity Control Master Account".  These accounts, however,                                 
            were corporate bank accounts in the names of "Oliver Q. Foust,                                 
            Accountancy Corporation DBA, O. Quay Financial Management                                      
            Corporation" and "Oliver Q. Foust, An Accountancy Corporation",                                
            respectively.  None of the checks were written on a personal bank                              
            account.                                                                                       
                  Based on this record, we conclude that petitioners have not                              
            presented sufficient evidence to prove that they personally                                    
            invested any funds in Vosburg.  In fact, the checks and the                                    
            corporate accounting records on which they rely indicate that the                              
            corporations treated the disbursements to Vosburg as assets of                                 
            the particular corporation.  Consequently, petitioners have                                    
            failed to demonstrate the necessary economic outlay to prove                                   
            basis.  They are not entitled, therefore, to deduct any losses                                 




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