- 571 - In summary, we hold that IRA is not entitled to bad debt deductions for partial worthlessness of the notes receivable in 1987. Issue 28. Whether IRA Is Entitled to Certain Capital Losses for 1987 FINDINGS OF FACT On its Federal income tax return for 1987, IRA reported capital losses as follows: Gross Date Date Sale Description Acquired Sold Price Basis Loss Int'l Films (IFI) 8/2/761987 -- $65,000 ($65,000) Brickell Biscayne 198312/22/87 $1,000 176,073 (175,073) Sandberg Village 197912/22/87 1,000 492,691 (491,691) 1984 Devel. Ltd. 198212/22/87 1,000 23,862 (22,862) Total 3,000 757,626 (754,626) In the notice of deficiency, respondent disallowed the claimed capital losses on the grounds that IRA did not establish its basis in the assets sold or disposed of, IRA did not demonstrate that the transactions had any substance, and the sales were to a related party and were subject to section 267, which disallows losses between related parties. IRA's records reflect that it sold its 1,500 shares of IFI stock to Gallenberger for $1 on September 28, 1988. An entry recording the September 1988 sale to Gallenberger was made on IRA's 1988 ledger. Subsequently, adjusting journal entries were made to IRA's books and records to reverse the 1988 entry as a sale of the stock and to reflect on IRA's books a writeoff of thePage: Previous 561 562 563 564 565 566 567 568 569 570 571 572 573 574 575 576 577 578 579 580 Next
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