Robert A. Read - Page 11

                                       - 11 -                                         
          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.             

          petitioner claims became worthless, petitioner did not argue, and           
          we need not decide, that the debt was partially worthless.                  

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  

Last modified: May 25, 2011