Joyce Aston - Page 2

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                         1.   Held: Neither BCCI, S.A., its IOMB, nor                 
                    its Los Angeles agency office meets the statutory                 
                    requirements for "qualified financial institution"                
                    pursuant to sec. 165(l)(3), I.R.C.  Accordingly,                  
                    petitioner is not entitled to a casualty loss in                  
                    1991.                                                             
                         2.   Held, further:  In light of the pendency                
                    of petitioner's claim in the liquidation of BCCI,                 
                    S.A., petitioner is not entitled to a bad debt                    
                    deduction pursuant to sec. 166, I.R.C., for 1991,                 
                    the year the funds were seized, because she failed                
                    to prove that the deposit became worthless during                 
                    that year.                                                        

               Carol P. Schaner and Paul W. Raymond, for petitioner.                  
               Louis B. Jack, for respondent.                                         



               JACOBS, Judge: Respondent determined the following                     
          deficiencies in petitioner's Federal income taxes:                          
                         Year                Deficiency                               
                         1988                $37,775                                  
                         1989                2,690                                    
                         1991                10,258                                   
               The issues for decision are: (1) Whether petitioner incurred           
          a loss on a deposit in a "qualified financial institution" within           
          the meaning of section 165(l)(3) and, if petitioner's loss does not         
          come within the purview of section 165(l), then (2) whether                 
          petitioner incurred a deductible  nonbusiness bad debt pursuant to          
          section 166.                                                                
               Unless otherwise indicated, all section references are to the          
          Internal Revenue Code in effect for the years under consideration.          




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