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the MacCoon note became worthless in 1988. Accordingly,
petitioners are not entitled to a section 166(a) loss for 1988.
II. Buck Sales
FINDINGS OF FACT
In 1986 and early 1987, petitioner spent approximately
$76,000 as a result of his involvement with an entity known as
Buck Sales. Petitioner spent approximately $20,000 on travel,
lodging, and food expenses for himself and six other individuals.
In addition, petitioner spent $18,700 on consulting fees and
approximately $38,000 on legal fees. Petitioners claimed these
amounts on their 1987 return as a long-term capital loss.
Respondent disallowed the $76,087 long-term capital loss
carryover on petitioners’ 1988 return.
OPINION
The next issue for our consideration is whether petitioners
are entitled to a $76,087 long-term capital loss relating to
purported investments in Buck Sales. Petitioner argues that he
spent approximately $76,000 in 1986 and early 1987 investigating
an investment opportunity in Hong Kong. Petitioner contends that
such amounts are deductible as a long-term capital loss.
Respondent contends that petitioners have failed to establish
that any of the payments are associated with any particular
investment or business. We agree with respondent.
Petitioner’s testimony concerning his involvement with Buck
Sales was vague and unconvincing. At the conclusion of his
testimony, it was not possible to understand the nature of
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