Santar S. Yei and Grace H. Yei - Page 12

                                         -12-                                          
          indication that any of the $3,500 was a loan from petitioners to             
          Cirtex.  Assuming that the $3,500 was a loan, and not a capital              
          contribution, petitioners offered no evidence to prove that the              
          unreimbursed portion ($1,500) became worthless.  Petitioners failed          
          to satisfy their burden of proof establishing the existence of the           
          claimed loan as well as the year in which the purported loan became          
          worthless.  They are thus not entitled to a bad debt deduction with          
          respect to this purported loan.                                              
               Petitioners claim they paid $4,000 to Esstec, a                         
          nonincorporated business, on behalf of Cirtex.  The owner of                 
          Esstec, Stephen Williams, also was a Cirtex employee and had rented          
          space in Cirtex's building. Cirtex did not provide a note to                 
          evidence petitioners' payment on its behalf.  The only evidence              
          presented was petitioners' check, dated July 11, 1988, made payable          
          to Esstec.  The notation at the bottom of the check stated "Esstec           
          loan".  Mrs. Yei testified that Esstec went out of business in               
          1989, but her testimony in this regard was not credible.                     
          Petitioners did not satisfy their burden of proof to establish the           
          identity of the borrower, the existence of a loan, or the year in            
          which the purported loan became worthless.  Thus, they are not               
          entitled to a bad debt deduction with respect to this purported              
          loan.                                                                        
               Petitioners sold an automobile to Stephen Williams for $2,000           
          in 1988, reporting $500 in income on their 1988 return and $1,500            
          in income on their 1989 return.  Petitioners claim that they did             




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