- 62 - (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.Page: Previous 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 Next
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