French E. Hickman and Janice C. Hickman - Page 26

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          Bancshares, and Midwest Bancshares, and (3) the director and                
          chairman of the board of directors of Nichols Hills Bank and                
          Trust.  As such, he was aware of the financial and business                 
          circumstances of those organizations.                                       
               To support their position that they acted reasonably in                
          claiming the 1992 and 1993 deductions relating to their claimed             
          1992 worthless stock loss, petitioners point to the following:              
          (1) The parties' stipulations (a) that at the end of 1991 Na-               
          tional Bank of Harrah and Harrah Bancshares had a combined net              
          operating loss carryforward of $1,236,093 and (b) that peti-                
          tioner's Harrah Bancshares stock was canceled on April 6, 1993,             
          when Harrah Bancshares merged with Midwest Bancshares, and                  
          (2) petitioner's testimony that "Harrah had become insolvent".              
          Petitioners presented no documentary or other evidence corrobo-             
          rating petitioner's testimony that "Harrah had become insolvent"            
          or clarifying the date on which petitioners claim "Harrah had               
          become insolvent".  In addition, petitioners disregard peti-                
          tioner's testimony that National Bank of Harrah was an operating            
          bank at the end of 1992.                                                    
               Based on our examination of the entire record before us, we            
          find that petitioners have failed to show that they acted with              
          reasonable cause and in good faith, or that they otherwise                  
          exercised due care or made a reasonable attempt to comply with              
          the Code, when they claimed the 1992 and 1993 deductions relating           





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