- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011