- 2 - decision is whether petitioners are entitled to a nonbusiness bad debt deduction pursuant to section 166. Background Some of the facts have been stipulated, and they are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Mr. Bauer resided in Riverside, California, and Mrs. Bauer resided in Laughlin, Nevada, at the time they filed their petition. Mrs. Bauer is a real estate broker. Mr. Bauer is a machinist. During the year at issue, Mr. Bauer spent his weekends with Mrs. Bauer in Laughlin, Nevada, and in Bullhead City, Arizona, a town located directly across the Colorado River from Laughlin. Petitioners, but especially Mrs. Bauer, frequently dined at a restaurant in Bullhead City named The Diamond Lil’s Drunken Lobster (the Drunken Lobster). The Drunken Lobster was an upscale restaurant specializing in steak and lobster that opened in 1990. The Drunken Lobster was owned and operated by father and son, Salvatore and John Dubato (John) (collectively referred to as the Dubatos), who also were petitioners’ personal friends. During 1991, the Drunken Lobster was having financial problems. The Dubatos approached petitioners for a loan, and petitioners decided to advance them funds for use in their business. Petitioners made a series of four interest-free loansPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011