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consideration, and all Rule references are to this Court’s Rules
of Practice and Procedure.
Following concessions, the issues for our consideration are:
(1) Whether petitioners are entitled to claim a short-term
capital loss relating to a purported $65,000 loan to Grant
MacCoon for 1988; (2) whether petitioners are entitled to a
$76,087 long-term capital loss for purported investments in “Buck
Sales” for 1988; (3) whether petitioners are entitled to
$147,0001 in bad debt losses claimed for 1989; (4) whether
petitioners overstated their 1988 capital gains by $36,000; and
(5) whether petitioners are liable for the delinquency and
negligence additions for 1988 and an accuracy-related penalty for
1989. Separate findings of fact and opinion are hereafter set
forth with respect to each of the first four issues. Those
portions of the stipulation of facts that pertain to a particular
issue are incorporated by this reference in the findings of fact
for the issue to which they relate.
1 Petitioners claimed $156,879 in deductions on their 1989
Federal income tax return, the entire amount of which was
disallowed by respondent. Respondent has conceded that
petitioners are entitled to deduct $6,500 of expenses. Of the
$156,879 claimed, $147,000 was claimed as bad debt losses.
Petitioners presented no evidence with respect to the $3,379
difference (between $150,379 and $147,000), and thus we treat
this as a concession by petitioners. Theodore v. Commissioner,
38 T.C. 1011, 1041 (1962).
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