Salvador A. and Kathleen M. Gaudiano - Page 13

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          accept that premise arguendo, petitioners bear the burden of                
          proving that the method they used to compute the amount realized            
          was reasonable in light of the facts and circumstances.                     
               S. Gaudiano testified that he computed the amount realized             
          of $145,430 on Four A's amended Form 1120S using two different              
          methods:  (1) A balloon payment calculation using a normal                  
          banking rate of 11-1/4 percent and (2) a junk bond calculation              
          using a 24- to 25-percent discount rate.  S. Gaudiano testified             
          that the two methods reached similar results.                               
               Neither Four A nor petitioners showed the present value                
          calculations on their amended returns, and during his testimony             
          S. Gaudiano failed to explain to the Court how either of his two            
          alleged methods arrived at an amount realized of $145,430.  From            
          the record, we are unable to discern the specific methodology               
          employed by S. Gaudiano in making the present value calculations.           
          Thus, petitioners have failed to establish that the method they             
          used to compute the amount realized of the note was reasonable or           
          had a basis in fact.  We conclude that petitioners have not                 
          established that they are entitled to increase their section 1231           
          losses relating to the sale of the equipment by Four A.                     
          III.  Bad Debt Deduction                                                    
               From 1988 to May 6, 1991, Appolo advanced significant                  
          amounts of money to Four A for its working capital needs.  In               
          1991, petitioners, in their capacity as Four A shareholders,                





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