- 2 - Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. All dollar amounts are rounded to the nearest dollar, unless otherwise indicated. References to petitioner are to August V. Klaue. The issues for decision are whether petitioners are entitled to a nonbusiness bad debt deduction of $266,323 in 1993; and if so, whether they are entitled to a capital loss carryover in the amount of $184,138 in 1994. We hold they are to the extent set out below.1 FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulated facts and the accompanying exhibits are incorporated into our findings by this reference. At the time the petitions in these cases were filed, petitioners resided in Spokane, Washington. Petitioner is a sophisticated businessman, and at the time of trial he was chairman of the board of five corporations which were engaged in banking, lumbering, and aviation. In the mid- 1970's, petitioner befriended Roger Estes (Estes). Estes is an 1Respondent determined that for the years at issue certain computational adjustments should be made which would reduce petitioners' itemized deductions. The parties can make these adjustments in their Rule 155 computation.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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