Stan Pyron and Ruth S. Pyron - Page 2

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               After concessions,1 the issues to be decided are as follows:           
               1.  Whether petitioners are entitled to deduct for taxable             
          year 1990 the portion of a loss carryforward attributable to a              
          bad debt deduction claimed by petitioners on their amended 1989             
          tax return for the worthlessness of loans made by petitioner Stan           
          Pyron to a mining company; and                                              
               2.  whether petitioners are entitled to a business bad debt            
          deduction for taxable year 1990 for the worthlessness of loans              
          made by petitioner to a mining company.                                     
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated for trial pursuant to           
          Rule 91.  The parties' stipulations of fact are incorporated                
          herein by reference and are found as facts in the instant case.             
               At the time they filed their petition in the instant case,             
          petitioners resided in Florence, Montana.                                   
               During 1979, petitioner Stan Pyron (petitioner) and Gerald             
          Dalton began investing in a Chilean copper mine of a mining                 
          company called Compania Minera Esperanza (CME).  During 1984 or             


          1    In the notice of deficiency, respondent disallowed, inter              
          alia, the bad debt deduction claimed by petitioners on their 1990           
          return for the worthlessness of loans in the amount of $47,938              
          made by petitioner Stan Pyron to Gerald Dalton, a business                  
          associate.  Respondent disallowed the deduction on the grounds              
          that the debt became worthless in taxable year 1988.  At trial,             
          petitioners' counsel conceded that "1988 is the correct year for            
          whatever consequence flows from the Dalton activities."  As 1988            
          is not a taxable year before us, we do not address the bad debt             
          deduction for the loans in the amount of $47,938 made by                    
          petitioner to Mr. Dalton.                                                   




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