- 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   NextLast modified: May 25, 2011