Wilburn C. Hall, Jr. - Page 62

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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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