- 22 -
Nor did we find the testimony of Matthew Roman, petitioner's
son, particularly helpful to petitioner's position that during
1990 and 1991 he was engaged in the business of buying, repair-
ing, and reselling automobiles. Indeed, although he testified
that during 1990 petitioner paid him for "bookkeeping, filing,
automobile detailing * * * and long-range business planning",
Matthew Roman did not even know the nature of the business in
which petitioner was allegedly engaged and for which he allegedly
worked during 1990 and 1991. On cross-examination, respondent's
counsel asked petitioner's son to describe the type of business
in which his father was engaged during 1990. Petitioner's son
replied: "I believe the -- well, at that time the name of his
business was TFC Engineering. And the scope of that is beyond my
knowledge."
Based on the entire record before us, we find that peti-
tioner has failed to satisfy his burden of proving that during
1990 and 1991 he was engaged under the name TFC Engineering (or
under any other name) in a trade or business within the meaning
of section 162(a) of purchasing, repairing, and reselling automo-
biles. Accordingly, petitioner is not entitled to any of the
deductions that he claims for those years with respect to such
alleged business of TFC Engineering.
Claimed Stock Sale Losses, Nonbusiness
Bad Debts, and Worthless Stock
Claimed Stock Sale Losses
Petitioner claims that during 1989 he realized long-term
Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 NextLast modified: May 25, 2011