William Spencer Bach and Barbara Ruth Bach - Page 12

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          from ISI to the various partnerships.  These documents were not             
          admitted as evidence.  However, even if we were to accept these             
          documents as proof of partnership debts to ISI, petitioners have            
          not offered any documentation which would confirm that ISI owed             
          petitioners a similar amount.  In an attempt to prove that such a           
          debt existed, petitioners offered ISI's general ledger as of                
          December 31, 1986, which reflects that payments were made from              
          ISI to petitioners and from petitioners to ISI.  However, as of             
          the end of 1986, the general ledger shows total officer loans               
          payable of $12,070.15.8  Such a small debt to petitioners during            
          1986 does not support their claims that there was in excess of $1           
          million in loans that became worthless in 1987.                             
               With regard to the $1,042,809.42 allegedly lent by                     
          petitioners to the various partnerships via ISI, we find that               
          petitioners have not met their burden of proving that a bona fide           
          debt existed.  The only evidence in support of petitioners'                 
          argument is Mr. Bach's own self-serving testimony.  No notes were           
          executed, no due date or interest rate was established, and no              
          security was offered or taken.  Therefore, we deny all of                   


               8The "Officer Loan Payable" account shows a number of                  
          "loans" from Mr. Bach to ISI and shows payments either to Mr.               
          Bach or to other vendors on behalf of Mr. Bach.  The beginning              
          balance of the Officer Loan Payable account is zero, and the                
          balance at the end of the year is $12,070.15.  We also note that            
          many of the cash payments, which reduce ISI's payable to Mr. Bach           
          during 1986, were listed as payments for, among other things,               
          country club dues, a yacht, petitioners' Jaguar automobile, and             
          the automobiles of petitioners' daughters.                                  




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