- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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