James K. Wise and Claudia R. Wise - Page 8

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          F.K. Wise.  The amount included the annual installment payment of           
          $3,000, due in August 1985, and an additional amount of $3,000.             
          The interest due at the time of the 1985 installment payment was            
          $2,773.                                                                     
               On their Federal income tax return for 1985, petitioners               
          claimed deductions for business bad debts as follows:                       
          Miscellaneous--$1,545; Texaroda--$30,000;5 Wood--$53,919; and               
          Heger and Wood--$50,000.6                                                   
               Petitioners delivered their 1985 Federal income tax return             
          to an individual who came to San Marcos to pick up tax returns              
          for filing with the Internal Revenue Service (IRS).                         
                                        OPINION                                       
          Issue 1. Bad Debt Deductions                                                
               Respondent disallowed all of petitioners' bad debt                     
          deductions claimed on their 1985 Federal income tax return.                 
          Petitioners argue that petitioner was liable as guarantor for               
          business-related debts of the various oil and gas entities, and             
          consequently they are entitled to deductions for payments made on           
          the entities' obligations.  Furthermore, petitioners claim that a           
          business-related debt owed to petitioner became worthless in                
          1985.                                                                       


          5                                                                           
               On their amended Federal income tax return for 1985,                   
          petitioners reduced this deduction to $15,000.                              
          6                                                                           
               This deduction was claimed on petitioners' amended return.             





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