-33--33-
Petitioners bear the burden of proving that the Speck debt
became worthless within the 1986 taxable year. Rule 142(a);
Rockwell v. Commissioner, 512 F.2d 882 (9th Cir. 1975), affg.
T.C. Memo. 1972-133; Crown v. Commissioner, 77 T.C. 582, 598
(1981). Specifically, petitioners must prove that the debt had
value at the beginning of the taxable year and that it became
worthless during that year. Estate of Mann v. United States, 731
F.2d 267, 275 (5th Cir. 1984); American Offshore, Inc. v.
Commissioner, 97 T.C. 579, 593 (1991).
There is no standard test or formula for determining
worthlessness within a given taxable year. Crown v.
Commissioner, supra at 598. The determination depends upon the
particular facts and circumstances of the case. Generally,
however, the year of the worthlessness is fixed by identifiable
events that form the basis of reasonable grounds for abandoning
any hope of recovery. United States v. S. S. White Dental
Manufacturing Co., 274 U.S. 398 (1927); American Offshore, Inc.
v. Commissioner, supra at 593; Crown v. Commissioner, supra at
598; Dallmeyer v. Commissioner, 14 T.C. 1282, 1292 (1950).
Worthlessness is determined primarily by objective standards.
American Offshore, Inc. v. Commissioner, supra at 594; Perry v.
Commissioner, 22 T.C. 968, 973 (1954).
The amounts due from Speck under the 1985 agreement were
overdue, but the fact that accounts are overdue, standing alone,
does not warrant deducting them as worthless. See Shippen v.
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