- 4 - $75,000 claim in the bankruptcy proceeding. Ultimately, Mr. and Mrs. Bogue received a discharge from bankruptcy and relief from their debts, including petitioners’ claim. In the preparation of their 1992 income tax return, petitioners were advised by their accountant that the claim against Mr. Bogue could be deducted as a bad debt against petitioners’ long-term capital gains. During 1993, when petitioners were compiling information for the preparation of their 1992 income tax return, they performed a more thorough analysis of the total amount that had been advanced to Mr. Bogue over the years. Based on their analysis of numerous documents, petitioners calculated that the total outstanding advances made to or on behalf of Mr. Bogue was $145,267, and they claimed that amount as a bad-debt loss on their 1992 return. Petitioners produced substantial amounts of documentation reflecting that they had made numerous advances to and on behalf of Mr. Bogue, beginning in 1987. OPINION We must determine whether the advances made by petitioners represent loans to Mrs. Kidder’s son, and if so, whether the loans became worthless in 1992. In general, section 166(a)2 2 All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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