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Ridgway's check were bona fide debts within the meaning of sec-
tion 166 and (2) that, assuming arguendo that such amounts were
bona fide debts, they became worthless during 1989. Accordingly,
we reject petitioner's claim that he is entitled for that year to
treat such amounts as nonbusiness bad debts.
Claimed Worthless Stock
Petitioner contends that the 3,000 shares of Celebration
common stock that he purchased on April 17, 1987, and May 14,
1988, became worthless during 1989 and that he is entitled for
that year to treat that stock as worthless stock under section
165(g).
Section 165(a) and (g) permits a capital loss deduction for
worthless stock for the taxable year during which such stock
becomes worthless. Our resolution of the question presented here
under section 165(g) depends on the facts and circumstances
relating to the Celebration stock at issue. See Lincoln v.
Commissioner, 24 T.C. 669, 694 (1955), affd. 242 F.2d 748 (6th
Cir. 1957).
The only evidence presented by petitioner about the worth-
lessness of the Celebration stock is his testimony that he
determined during 1989 that Mr. Parra was unable to make Celebra-
tion into a successful business. Petitioner's belief that the
Celebration stock at issue became worthless during 1989 is not
enough to persuade us that that stock did become worthless during
that year. See Aagaard v. Commissioner, supra.
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