Richard A. and Carol B. Little - Page 34

                                       - 34 -                                         
               Respondent contends that testimony by Hodges and Hogue                 
          shows that Dondi Financial stock lost its value before 1984.                
          As stated above, Hodges' and Hogue's testimony is inadmissible.             
          See par. B, p. 17.  However, even if we considered their                    
          testimony, our conclusion would remain the same.                            
               Hodges and Hogue testified about criminal activities by                
          Vernon officers.  Hodges said that the FBI agents did not                   
          consider the financial impact those activities had on Vernon                
          or Dondi Financial.  Their testimony about Vernon's financial               
          status consisted of examples of bad loans and accounting                    
          misrepresentations of delinquent loans to the Federal regulatory            
          authorities and was based on the 302 reports, some of which were            
          prepared by other agents.  The testimony, although marginally               
          relevant to the liquidating value analysis, is not helpful in               
          deciding whether Dondi Financial stock had potential value.                 
               As stated above, we conclude that petitioners' Dondi                   
          Financial stock became worthless in 1987.                                   
               3.   Conclusion                                                        
               We hold that petitioners may deduct $727,600 in 1987 for               
          worthless Dondi Financial stock.4                                           
          D.   Texana Capital Stock                                                   
               1.   Notice of Deficiency                                              


               4 Respondent does not contend, and we therefore need not               
          consider, whether petitioners had any debt-forgiveness income in            
          respect of the Dondi Financial stock in 1987 or 1988.                       




Page:  Previous  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  34  35  36  37  Next

Last modified: May 25, 2011