- 6 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011