Alfred C. Heston - Page 2

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          Federal income tax in the amount of $6,287.                                 
                    After petitioner's concessions2, the sole issue for               
          decision is whether petitioner is entitled to deduct an ordinary            
          loss in the amount of $18,750 as a result of his investment in              
          Geotech Energy Corporation.                                                 
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             
          herein by this reference.  Petitioner resided in Spokane,                   
          Washington, on the date the petition was filed in this case.                
          Petitioner was married during the year in issue and filed a 1991            
          joint Federal income tax return with his wife.  A statutory                 
          notice of deficiency was mailed to petitioner and his wife.                 
          However, only petitioner Alfred C. Heston has filed a petition              
          with this Court.                                                            
               According to his testimony in November 1987, petitioner                
          invested $18,750 in Geotech Energy Corporation (hereinafter                 
          Geotech) to purchase a 1/4 percent overriding royalty interest in           
          the Rio Blanco County, Colorado oil, gas, and other mineral lease           
          that had been procured by Geotech (hereinafter Rio Blanco lease).           
          Petitioner testified that Geotech obtained oil leases and sold              
          overriding royalty interests in those oil leases to individual              

          2         In her notice of deficiency, respondent determined that           
          petitioner's employee business expenses should be disallowed to             
          the extent of $1,775 and a $10,000 long-term capital loss should            
          be recharacterized as a nonbusiness bad debt, and therefore                 
          deducted as a short-term capital loss.  Petitioner concedes these           
          issues.                                                                     




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