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made by petitioner to Color Trick, Inc. (Color Trick); and (2)
whether petitioner may claim an ordinary loss pursuant to section
1244 attributable to the worthlessness of his stock in Color
Trick. Unless otherwise noted, all section references are to the
Internal Revenue Code as in effect for the year in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts and certain exhibits have been stipulated
for trial pursuant to Rule 91. The stipulated facts are
incorporated herein by reference and are found accordingly.
At the time he filed the petition in the instant case,
petitioner resided in Dunedin, Florida.
Beginning in 1978 and during the times relevant to the
instant case, petitioner was an anesthesiologist. During 1980,
petitioner and certain other anesthesiologists formed a
partnership known as Anesthesia Associates of Dunedin (medical
group) that provided services at a local hospital. Petitioner
handled operation of the medical group. Petitioner worked
between 40 and 50 hours per week as an anesthesiologist and took
18 weeks of vacation per year.
From 1980 until 1984 or 1985, petitioner invested with a
builder in the construction and sale of homes on speculation.
Additionally, petitioner and another physician in the medical
group owned an apartment building. Petitioner maintained the
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