- 7 - Petitioner reported the income or loss connected with Cinevision as passive income or loss on his 1987 through 1989 returns. On his 1989 Federal income tax return, petitioner claimed a business bad debt deduction with respect to his loans to Color Trick in the amount of $269,129. Petitioner’s Federal income tax returns for taxable years 1987 through 1990 contain no other reference to any lending activity of petitioner. OPINION The first issue we consider is whether petitioner is entitled to a business bad debt deduction pursuant to section 166(a)(1) for the worthlessness1 of petitioner’s loans and advances to Color Trick. That section provides, in general, for the deduction of debts that become wholly worthless during a taxable year. Section 166(d), however, limits the general rule, providing that, in the case of a taxpayer other than a corporation, nonbusiness bad debts are to be treated as short- term capital losses.2 In general, a nonbusiness bad debt is a 1 Respondent does not contest the fact that petitioner's loans to Color Trick became worthless during 1989. 2 Sec. 166(d) provides: SEC. 166(d). Nonbusiness debts.-- (1) General rule.--In the case of a taxpayer other than a corporation-- (A) subsection (a) shall not apply to any (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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