Thomas A. and Maria M. Hagman - Page 2




                                        - 2 -                                          

          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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