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Court is not bound to accept the unverified, undocumented
testimony of petitioner. Hradesky v. Commissioner, 65 T.C. 87,
90 (1975), affd. per curiam 540 F.2d 821 (5th Cir. 1976). More
is required by the Court than petitioner's unsubstantiated,
unverified, undocumented testimony. Wood v. Commissioner, 338
F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C. 593 (1964).
In general, section 165(g) provides that if any security
(including stock) that is a capital asset becomes worthless
during the taxable year, the loss resulting therefrom shall be
treated as a loss from the sale or exchange, on the last day of
the taxable year, of a capital asset.
The allowable amount of the loss is the adjusted basis of
the security provided in section 1011 for purposes of determining
the loss from the sale or other disposition of property. Sec.
165(b). Furthermore, losses from the sale or exchange of a
capital asset shall be allowed only to the extent allowed in
sections 1211 and 1212. Pursuant to sections 1211 and 1212,
losses in excess of gains from the sale or exchange of capital
assets shall be allowed only to the extent of $3,000 per year
($1,500 per year in the case of a married individual filing a
separate return) with any excess capital loss being carried
forward to subsequent tax years. Secs. 1211, 1212.
Section 1244(a), however, allows an individual taxpayer to
treat a loss on "section 1244 stock" as an ordinary loss where it
would otherwise be treated as a loss from the sale or exchange of
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