-12- Cities’ image, viewed from the perspective of Ms. Jackson’s letter, was flat and without potential. Ms. Jackson attempted to assure petitioner that she intended to repay him. Repayment, however, would have to come from unidentified sources and/or uninitiated businesses that Ms. Jackson intended to start. One such idea concerned an entity to be entitled "Dancer", in which Ms. Jackson offered petitioner 25,000 shares with a stated or par value of $750,000. On April 17, 1990, Cities filed for relief under chapter 11 of the U.S. Bankruptcy Code. Petitioner was not listed as a creditor in Cities’ bankruptcy petition. However, the proceeding was converted to a liquidating bankruptcy, under chapter 7 of the U.S. Bankruptcy Code. In that connection, on June 26, 1991, Ms. Jackson filed an amended bankruptcy petition listing petitioner as a creditor for $659,000. As of the end of 1988, petitioner believed that his claim against Ms. Jackson or Cities was worthless, and he did not commence any action against them to recover his funds. On petitioner's 1988 return, his accountant reported a long-term capital loss in the amount of $186,280 in connection with funds advanced. Petitioner now claims an ordinary loss for 1986 and 1987 or 1988 with respect to the $677,652.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011