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closed and completed transactions, fixed by identifiable events,
and * * * actually sustained during the taxable year.”
Petitioners argue that they are entitled to a $27,30011 loss
pursuant to section 165 with respect to petitioner’s investment in
the FoodSource program. Respondent contends that petitioner did
not enter into the FoodSource program primarily for profit and
therefore petitioners are not entitled to the loss claimed. See
Fox v. Commissioner, 82 T.C. 1001, 1021 (1984).
The only evidence petitioners presented in this regard was
petitioner’s blanket assertion that he possessed a profit motive
in entering the FoodSource investment. We are not required to, and
do not, accept this blanket self-serving assertion. Petitioner
attempted in 1984 to recoup his lost investment from prior years.
He has failed to show that he entered into the FoodSource program
primarily for profit or that he sustained any business-related loss
in 1984.
We conclude that petitioners are not entitled to a section 165
deduction in 1984 for the $27,300 invested in the FoodSource
program.
To reflect the foregoing,
Decision will be
entered for respondent.
11 Petitioner contends that $27,300 is the amount of his
cash investment in the FoodSource program.
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