Richard Soo Kim and Donna Kim - Page 2

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          After concessions, the only issue remaining for decision is                 
          whether petitioners are entitled to a bad debt deduction for 1990           
          in the amount of $30,500.                                                   
          Some of the facts have been stipulated, and the stipulated                  
          facts are incorporated herein by this reference.  At the time the           
          petition was filed, petitioners resided in Kirkland, Washington.            
          Richard Soo Kim (petitioner) owned a business that operated                 
          as a subcontractor for various garment manufacturers.                       
          Petitioner's employees would sew and press the garments before              
          they were packed and returned to the manufacturers.                         
          Petitioner contends that garments in his possession, which                  
          belonged to certain manufacturers, were stolen by one of his                
          employees.  In order to repay the manufacturers for the missing             
          garments, petitioner reduced the amount of future invoices to the           
          manufacturers by the value of the garments.  Petitioner deducted            
          the amount of the invoice reductions on Schedule C, Profit or               
          Loss From Business, attached to petitioners' 1990 Form 1040,                
          U.S.,Individual Income Tax Return.  Petitioners' apparent                   
          position is that, because subsequent invoices were reduced, the             
          business did not receive certain income from services the                   
          business performed for the manufacturers.  This reduction,                  
          petitioners allege, is a business bad debt.                                 
          Petitioners bear the burden of proving that they are                        
          entitled to any claimed deduction.  Rule 142(a); INDOPCO, Inc. v.           
          Commissioner, 503 U.S. 79, 84 (1992).   This includes                       




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