-34- 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 agreementPage: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
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