Charles J. Dugan - Page 18

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          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 the             




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