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Neither petitioner nor his parents could provide any
specifics about the claimed loans. No documentation or other
objective indicia of a bona fide debt were introduced. On the
minimal evidence presented, and in view of the family
relationship, we cannot conclude that there was any bona fide
obligation between petitioner's parents and petitioner. See
Perry v. Commissioner, 92 T.C. 470, 481 (1989), affd. without
published opinion 912 F.2d 1466 (5th Cir. 1990).
Petitioner also argues that no sale of the World
Medical/Dental practice to Dr. Kay was ever consummated.
Petitioner does not deny, however, that he was the owner of the
equipment, furniture, and supplies of World Medical/Dental at the
time the alleged sale occurred. That the sale to Dr. Kay was not
completed does not exclude from gross income any money received
by petitioner in contemplation of the sale of his equipment that
was part of World Medical/Dental.
Dr. Kay testified that the money that she paid to
petitioner's mother was a downpayment on the purchase of World
Medical/Dental. Dr. Kay also testified that she never received
any of the assets of World Medical/Dental and that she was never
refunded any portion of her downpayment. According to Dr. Kay's
testimony, World Medical/Dental was suddenly closed in April 1991
without any explanation.
Petitioner's only explanation at trial for Dr. Kay's
payments is that the $63,000 received by World Medical/Dental
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