- 3 - On September 29, 1993, petitioner wrote a letter to AWS requesting that his four units in WCTVA be redeemed for the amount of his original investment, $25,000, plus 10-percent interest. He again requested a return of his investment in a letter to AWS dated October 10, 1993. He received no response to these two letters. On October 14, 1993, petitioner tried to telephone AWS but was only able to reach its answering service. Since October 1993, petitioner has made numerous attempts to contact AWS and has sought the assistance of several government agencies and courts in his effort to recover his investment. Petitioner did not claim a loss with respect to his investment with AWS on his 1993 return. He first considered claiming a loss at the suggestion of one of respondent's revenue agents during an audit of his 1993 return. Section 165(a) allows as a deduction any loss sustained during the taxable year and not compensated for by insurance or otherwise. In the case of an individual, the deduction is allowable for losses incurred in any transaction entered into for profit. Sec. 165(c)(2). Respondent argues that any loss that petitioner incurred with respect to his investment with AWS was not sustained during his 1993 taxable year. With respect to the proper year to claim a deduction for a loss, section 1.165-1(d), Income Tax Regs., provides:Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011