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Commissioner, 27 T.C. 330, 339 (1956), affd. 253 F.2d 928 (3d
Cir. 1958).
We also consider the fact that Drexel was current on its
interest obligations throughout 1989. On August 23 and December
19, 1989, Drexel made interest payments on the note, a factor
that weighs against worthlessness. Cole v. Commissioner, 871
F.2d 64, 67 (7th Cir. 1989), affg. T.C. Memo. 1987-228.
Additionally, we consider the fact that the record is devoid
of any direct evidence of the worthlessness of the note.
Although petitioner testified at trial that he observed certain
events which he believed “could have impaired Drexel’s capital or
its ability to do business”, such as the resignation of Michael
Milken during June 1989, Drexel’s payment of $500 million in
fines and restitution during September 1989, and a 216-point drop
in the Dow Jones Industrial Average on October 13, 1989,
petitioner’s negative perceptions of Drexel’s condition, without
more, are inadequate to support a finding of worthlessness. Fox
v. Commissioner, supra at 822. Moreover, general unfavorable
circumstances have less to do with establishing worthlessness
than specific facts regarding the debtor’s assets and the amount
and validity of claims against it. Dallmeyer v. Commissioner, 14
T.C. 1282, 1292-1293 (1950).
Petitioners argue that Drexel itself viewed the note as
worthless. Petitioners rely on the fact that the notation “N/A”
appears beneath the words “Market Value” in monthly statements
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