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and Mr. Trueheart did not render any services for petitioner
after 1990.
Petitioner paid Mr. Trueheart $1,000 in December 1990 for
Mr. Trueheart's services. Petitioner did not pay Mr. Trueheart
any further amount.
Petitioner continued to engage in the commercial real estate
market in 1991 and 1992. Petitioner reported income and expense
from his commercial real estate activities for those years on
Schedules C (Profit or Loss from Business). On his Schedule C
for 1991, petitioner deducted travel expense in the amount of
$9,509.
In mid-1992, approximately 1-1/2 years after Mr.
Trueheart's letter dated December 20, 1990, petitioner flew to
Texas and met with Mr. Trueheart's associate Dan Bendinger (Mr.
Bendinger) ostensibly to discuss options for recovering the
$55,000. Mr. Bendinger reported to petitioner that no work had
been performed on petitioner's case since 1990 and that the
prospects of recovering $55,000 from Mr. Suiter were poor.
Petitioner never filed a lawsuit to recover any amount from
Mr. Suiter.
On his Schedule C for 1992, petitioner deducted a loss in
the amount of $30,000 for "exten[s]ion consideration fee to Darby
Suiter of Houston, Texas for investment purchase". Petitioner
did not deduct on his 1992 Schedule C the additional $25,000 fee
paid to Mr. Suiter in 1990.
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