- 3 - Some of the facts have been stipulated and are so found. The stipulated facts and the accompanying exhibits are incorporated herein by this reference. At the time the petition in this case was filed, petitioners resided in Paradise Valley, Arizona. For convenience, we combine our findings of fact with our opinion under each separate issue heading.2 Issue 1. Bad Debt Respondent determined that for 1990 petitioners were not entitled to a $500,000 business bad debt deduction related to their disposition of Washington Chocolate. Section 166 entitles a taxpayer to a deduction for a bad debt that becomes worthless during the taxable year. A business bad debt can be deducted from ordinary income if it is either partially or totally worthless. Sec. 166(a). Only a bona fide debt is deductible. Sec. 1.166-1(c), Income Tax Regs. Petitioners bear the burden of proving that a bona fide business debt exists and that the debt became worthless during the taxable year in issue. Rule 142(a); Crown v. Commissioner, 77 T.C. 582, 598 (1981); Rude v. Commissioner, 48 T.C. 165, 172 (1967). From July 25, 1986, until May 26, 1989, petitioners were the sole shareholders of Washington Chocolate, a subchapter S 2 We have considered each of the parties' arguments and, to the extent that they are not discussed herein, find them to be unconvincing.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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