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notes to the accountant for $1,000 evidenced the worthlessness of
the notes, that sale did not occur until December 21, 1993, at
the conclusion of K&H’s 1993 year and, hence, petitioner’s 1993
tax year. In addition, petitioner’s sale of his capital or
equity interest in Snacks has not been shown to have had any
particular effect on the worthlessness of the notes.
Accordingly, we find that petitioner has not substantiated his
claim for partial worthlessness of the notes during the years in
question.
Two remaining issues were addressed by the parties on
brief.6 The first involved $60,143 of Snacks’ operating expenses
that were paid and claimed by K&H for its taxable year ended
April 27, 1991. Respondent determined in the notice of
deficiency that the expenses “are not deductible because * * *
[they] were incurred on behalf of * * * [Snacks] and therefore
are not trade or business expenses of K&H”. On brief, respondent
maintained the position that the expenses were not K&H’s trade or
business expenses.
Generally, one taxpayer may not deduct expenses paid on
behalf of another taxpayer. See, e.g., Dietrick v. Commissioner,
881 F.2d 336, 339 (6th Cir. 1989), affg. T.C. Memo. 1988-180. We
6 To the extent that either party did not address an issue
raised by the pleadings, we assume that the issue has either been
agreed to by the parties or is being abandoned by the party with
the burden of proof.
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