- 55 - determine what portion of the bad debt deduction claimed on petitioner's return is attributable to fraud. The record is devoid of any evidence of loans being made to or by the partnerships. Meeks advised petitioner that he would have to file amended partnership returns to reflect the discharge of indebtedness income in order to claim the deduction. Petitioner knew that the deduction was improper and unsupportable. Petitioner did not follow the advice of his tax adviser. We conclude that the claimed deduction was for the sole purpose of evading tax. Accordingly, on the basis of the record, we hold that the amount of $2,035,424 which petitioner claimed as a bad debt deduction was fraudulent in its entirety. (6) The Ford Van As indicated, Forster presented petitioner with a personal check in the amount of $7,800, payable to a Ford dealership, to enable petitioner to purchase a van. Petitioner failed to report this amount in income on his 1982 return. Respondent asserts that the entire $7,800 is attributable to fraud. We hold that petitioner's failure to report the $7,800 on his 1982 return is fraudulent. Forster did not present the check to petitioner as a gift. Rather, petitioner coerced Forster by threatening to cancel Newtowne's project if Forster refused toPage: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Next
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