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fees. Additionally, in January 1989, VIP filed an affidavit of
judgment against M&G and MBG. Petitioner offered no evidence of
the financial condition of either M&G or MBG. Recovery of any
portion of the $709,660 judgment would have dramatically improved
VIP's financial condition. Given these facts, we cannot conclude
that petitioner's right of subrogation was worthless.
Accordingly, petitioner has not carried his burden of showing
that he had a debt which was worthless at the end of 1986.
To reflect the foregoing,
Decision will be
entered for respondent.
4(...continued)
petitioner claims became worthless, petitioner did not argue, and
we need not decide, that the debt was partially worthless.
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