Stanley P. Zurn - Page 34

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          to show a debtor-creditor relationship and that any such debt               
          became worthless in the taxable year.                                       
               Petitioner bears the burden of proving that respondent's               
          determination is in error by showing that he is entitled to a bad           
          debt loss.  Rule 142(a); Welch v. Helvering, 290 U.S. 111 (1933).           
          Although petitioner provided evidence reflecting that funds were            
          advanced to Mr. Pritchett during 1982, there has been no showing            
          that any debts due from Mr. Pritchett or investments in Mr.                 
          Pritchett’s enterprises became worthless during 1986 or any other           
          year currently before the Court.  Accordingly, we hold that                 
          petitioner has not shown his entitlement to a $35,000 bad debt              
          loss in connection with Mr. Pritchett for the 1986 taxable year.            
          Issue 6.  Whether Petitioner Is Liable for Additions To Tax for             
          Fraud or, in the Alternative, Additions to Tax for Negligence and           
          Delinquency                                                                 
               Respondent determined an addition to tax for fraud in each             
          of the 5 taxable years before the Court.  In addition to the                
          issues on which fact findings have already been made, respondent            
          relies on stipulated matters which were resolved due to                     
          petitioner’s concessions.                                                   
               During July 1988, petitioner negotiated the sale of the 3071           
          Harrington real property (Harrington property) and entered into             
          an escrow agreement with Hanmi Escrow Co. (Hanmi).  During August           
          1988, petitioner negotiated the sale of the 1149 Virgil real                
          property (Virgil property) and entered into an escrow agreement             






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