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of the note, "$10,000 plus interest". According to
petitioner, "ultimately, several years later, the stock
became worthless." Petitioner's testimony about how he
determined that the stock had become worthless and when
the worthlessness occurred is as follows:
Q How did you determine that the stock
became worthless?
A Well, the price started going down, and
finally it got down to a quarter, and then
finally it wasn't even listed. And finally
the company was put in bankruptcy and as far
as I --
Q Did that occur in 1986?
A I don't know when it occurred. I think
it did, but I couldn't say for sure.
Petitioners claim a deduction under section 165(g)
on the ground that the stock of Windsor Resources became
worthless in 1986. Even if we accept petitioner's
testimony that he borrowed $10,000 to invest in stock of
Windsor Resources, petitioners must still prove that the
stock became worthless in 1986. E.g., Boehm v. Commis-
sioner, 326 U.S. 287, 293-294 (1945).
In view of petitioner's testimony, we cannot find that
the stock of Windsor Resources became worthless in 1986.
Petitioner testified candidly: "I don't know when it [the
bankruptcy of Windsor Resources] occurred." Accordingly,
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