- 8 - with regard to Telim, that any such losses were incurred in 1990, that funds they paid to or on behalf of Telim (and on which the alleged bad debt losses are based) constituted loans, and that whatever losses petitioners incurred with regard to Telim constituted anything other than section 1244 losses. No credible evidence supports the existence of the alleged loans from petitioners to Telim. No promissory notes exist. No repayments were made to petitioners. To the contrary, with regard to funds petitioners paid to or on behalf of Telim petitioners were issued additional stock in Telim. Telim's corporate Federal income tax returns for 1987 and 1988 showed only small loans to shareholders, and Telim's corporate Federal income tax return for 1989 did not reflect any loans to shareholders. By the end of 1987, Telim had ceased operations. In 1988, Telim sold off its assets. In 1989, Telim filed its final tax return. On petitioners’ 1990 and 1991 joint Federal income tax returns as originally filed with respondent, petitioners did not claim any losses relating to petitioners’ investment in Telim. No credible evidence supports petitioners’ claim that their losses with regard to Telim should be treated as 1990 losses. In 1988, petitioners were authorized to sell off assets of Telim. The evidence does not establish what funds were realized on such sales and what portion thereof was retained byPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011