Douglas V. and Magdalene Merante - Page 12

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                  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.                                 

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