- 12 - Respondent contends that the advances were not worthless because Sheldon admitted that Time To Share had a receivable from Glen Ivy of a substantial amount at the end of 1990. We do not believe this allegation is significant in that Time To Share was having difficulty collecting from Glen Ivy for some time, indicating that Glen Ivy was probably in dire financial straits, as further evidenced by its filing for bankruptcy in 1991 or 1992. Moreover, petitioner would have had to obtain a judgment against Sheldon and/or Time To Share first and then proceed against Glen Ivy (probably along with numerous other creditors) at a prohibitive cost. This type of effort is not required to establish worthlessness. Accordingly, we hold that petitioners are entitled to a short term capital loss deduction of $3,000 on their 1990 return. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011