- 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
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