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quarter of 1987 (1987 Vanguard statement) to petitioner as
custodian for Matthew Roman under the UGMA of New Mexico that
indicated that 45 shares of Daisy Systems Corp. stock (Daisy
stock) and 200 shares of Gibraltar Financial Corp. stock (Gibral-
tar stock) had been purchased for $304 and $700, respectively.
Vanguard sent another statement for the last quarter of 1988
(1988 Vanguard statement) to petitioner as custodian for Matthew
Roman under the UGMA of New Mexico that showed that those stocks
were still being held. (Hereinafter, the 1987 Vanguard statement
and the 1988 Vanguard statement shall be referred to collectively
as the Vanguard statements.) Vanguard sent to petitioner as
custodian for Matthew Roman under the UGMA of New Mexico a form
in lieu of Form 1099-B for 1989 (Vanguard 1099) that indicated
that on April 27, 1989, the Daisy stock and the Gibraltar stock
were sold for $157 and $60, respectively.
Claimed Nonbusiness Bad Debts
Claimed Nonbusiness Bad Debts of Mr. Parra
On October 5, 1988, Richard L. Parra (Mr. Parra) signed a
note that stated that he was to repay Nathanael Roman $5,351 at
an annual percentage interest rate of 12.5 percent (October 5
note). Mr. Parra was to repay that note in monthly installments
of principal and interest totaling $179. On October 7, 1988, Mr.
Parra signed another note that stated that he was to repay
Nathanael Roman $5,020 at an annual percentage interest rate of
18.2 percent (October 7 note). Mr. Parra was to repay that note
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