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that Mr. McWilliams' note became worthless during 1989 is re-
quired to prove that it did become worthless during that year.
See Aagaard v. Commissioner, 56 T.C. 191, 209 (1971).
Based on our review of the instant record, we find that
petitioner has failed to carry his burden of proving that Mr.
McWilliams' note became worthless during 1989. Accordingly, we
sustain respondent's determination that petitioner is not enti-
tled for that year to treat any amount of Mr. McWilliams' note as
a nonbusiness bad debt.
Claimed Nonbusiness Bad Debts of Ms. Parra,
Ms. Parra and/or Mr. Parra, and Mr. Ridgway
Petitioner contends that he is entitled for 1989 to treat
the following as nonbusiness bad debts under section 166: The
amount of Ms. Parra's check; the undisclosed amounts of the
insurance payments that petitioner made; and the amount of Mr.
Ridgway's check. The record does not show that there was any
interest required to be paid on, that petitioner expected or
demanded repayment of, or that the alleged debtors believed that
they were required to repay those alleged loans. Nor does the
record show the financial condition of any of the alleged debtors
at the times (1) petitioner allegedly lent them the amounts in
question and (2) petitioner determined that the alleged loans
became worthless.
Based on our review of the instant record, we find that
petitioner has failed to carry his burden of proving (1) that the
amounts of Ms. Parra's check, the insurance payments, and Mr.
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