- 5 -
sought to recover his investment well beyond such date. We
conclude that petitioner's loss from his investment with AWS was
not fixed with reasonable certainty by the end of his 1993
taxable year. Accordingly, we hold that he is not entitled to a
deduction for any such loss for 1993 and thus did not make an
overpayment of tax.
To reflect the foregoing,
Decision will be entered
for petitioner as to the
deficiency and the penalty and
for respondent as to the
claimed overpayment.
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Last modified: May 25, 2011