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(3) "Write-offs", Bad Debts, Loan or Investment Loss
Petitioner claimed deductions of $137,000 for "write-offs" on
his tax return for 1982, $6,300 and $19,229 for bad debts on his
tax returns for 1983 and 1984, respectively, and $36,451 for loan
or investment loss on his tax return for 1985.
At trial, we cautioned petitioner that he would have to show
basis, year of worthlessness, and kind of transaction, in order
for us to determine (1) whether he was entitled to a deduction,
(2) what was the year and amount of any such deduction, and (3)
whether the deduction was ordinary (secs. 165(c)(1) and
166(a)(1)), short-term capital loss (secs. 165(g) and
166(d)(1)(B)), or long-term capital loss (sec. 165(g)). Petitioner
assured us that he would clarify these matters later. He failed to
do so. We assume he has abandoned these claims. See Sundstrand
Corp. v. Commissioner, 96 T.C. 266, 344 (1991); Money v.
Commissioner, 89 T.C. at 48. In any event, our inspection of the
record in the instant case fails to convince us that petitioner
suffered any deductible losses or bad debts during the years in
issue. Accordingly, petitioner has failed to meet even the minimal
requirements of Cohan and Gerling International on this issue.
We hold for respondent on this issue.
(4) Other Claimed Deductions
Petitioner spent $1,062 on 1982 Schedule C business expenses
for farming. Petitioner's Hall Farms business activity is not
incorporated, thus these expenses are not corporate expenses.
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