- 18 - which an estimate may be made. Vanicek v. Commissioner, 85 T.C. 731, 743 (1985). Without such a basis, any allowance would amount to unguided largesse. Williams v. United States, 245 F.2d 559, 560 (5th Cir. 1957). Since petitioner has not demonstrated a business purpose for these expenses, the claimed expenses are disallowed. Issue 5. The Capital Loss Deduction SDG was incorporated on June 1, 1981. On the date of its incorporation, 33 shares of stock were issued to petitioner at a cost of $1 per share. On November 30, 1981, petitioner transferred his automobile, valued at $2,600, to the corporation in exchange for 10 additional shares of stock. Shortly after its incorporation, petitioner realized that SDG needed additional short-term capital for its operating expenses. Petitioner approached an acquaintance, William J. Vaughn (Mr. Vaughn), with the prospect of investing in SDG. Mr. Vaughn expressed some concern regarding the safety of his investment. Accordingly, petitioner orally agreed to guarantee Mr. Vaughn's investment against a loss upon the liquidation of SDG. The agreement was never reduced to writing, nor did the parties discuss the method or schedule of payments under the guaranty. In the fall of 1981, Mr. Vaughn invested $15,000 in SDG in exchange for 60 shares of stock. When SDG was liquidated in November 1983, the outstanding loan balance due to petitioner from SDG totaled $8,650. At thePage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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