-6-
during the year in which the deduction is sought that rendered
the debt uncollectible." Greenberg v. Commissioner, T.C. Memo.
1992-292. Since petitioner is claiming a deduction for partial
worthlessness, which is not allowable as to nonbusiness debts,
and since petitioner failed in any case to establish that any
portion of the debt became worthless during 1993, no bad debt
deduction is allowable as to 1993.
In 1994, petitioner claimed a business bad debt deduction
for advances to the company amounting to $2,041,409. We note
initially that the amount petitioner claimed exceeds the amount
he advanced to the company. But the key weakness in petitioner's
position is that he once again fails to identify or demonstrate
any particular circumstance or set of circumstances that would
establish that his advances became worthless in 1994. Greenberg
v. Commissioner, supra. In fact, petitioner's actions are
inconsistent with the notion that the company became unable to
repay these advances in 1994. As late as October 1995,
petitioner was actively litigating against the company to collect
the December 1993 note. Since petitioner has failed to establish
that the debts became worthless in 1994, we need not decide
whether these advances constituted business as opposed to
nonbusiness debt.
As to the accuracy-related penalty, section 6662(a) imposes
such a penalty equal to 20 percent of the portion of an
underpayment that is attributable to, among other things,
negligence. In order to avoid this penalty, petitioner must
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