Christopher A. Boyko and Roberta A. Boyko - Page 6

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          concluded that the computer program was worthless.  Petitioner              
          paid Mr. Miller $17,715 for his services.                                   
               Following the investigation, petitioner decided to obtain a            
          full release from the computer leases.  On July 25, 1991,                   
          petitioner paid $26,750 to Orix Credit Alliance to obtain a full            
          release from all further obligations owed by him under the                  
          computer lease agreement assigned to Orix.  On July 30, 1991,               
          petitioner paid $3,800 to Fleet Credit Corp. to be released from            
          all further obligations owed by him under the computer lease                
          agreement with Fleet.  In April 1991, petitioner regained                   
          possession of the automobile that he had leased for the benefit             
          and use of Mr. Kelley, and paid Americana Leasing (successor to             
          Active Leasing) $10,155 for the purchase of the automobile.                 
               On November 5, 1992, petitioner obtained a judgment against            
          Multilogic for enforcement of the demand note.  Petitioner has              
          not received any payment on the judgment.  No criminal charges              
          were ever filed against Mr. Kelley.                                         
               On his 1991 return petitioner claimed a section 1244 stock             
          loss in the amount of $83,989 for funds invested in                         
          TIC/Multilogic, a $9,899 section 162 expense for amounts paid               
          under the computer leases, and a $17,715 legal and professional             
          fees expense for the payments to Mr. Miller.  Respondent                    
          determined that the losses were not allowable.                              







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