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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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