- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011