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petitioner has failed to demonstrate the amount of the debt. A
debt for purposes of section 166 must be an enforceable
obligation to pay a "fixed or determinable sum of money”. Sec.
1.166-1(c), Income Tax Regs. In Iowa S. Utils. Co., the debt had
been adjudicated, and the State court judgment served to make the
debt "a fixed or determinable sum" in the Court of Claims' view.
Iowa S. Utils. Co. v. United States, supra at 495. Here, the
only evidence of the amounts William diverted, which he disputes,
is the testimony of petitioner and his accountant that the ratio
of cash to total sales for the then-current 18-month period was
computed, and then an estimate of the cash sales for the years
1984 through 1990 was made by applying the current-period ratio
to actual sales in those past years. There is no evidence in the
record of the reasonableness of this estimate, the
appropriateness of applying the current ratio to past years, or
of any corporate records to support the accuracy of this
estimate. On this record, petitioner has failed to show that the
debt he alleges was of a "fixed or determinable" amount.
Second, petitioner has not shown that the debt became
worthless in 1992. Section 166 allows a deduction for debts
which become worthless "within the taxable year." To meet this
requirement, the taxpayer must prove that the debt had value at
the commencement of the year for which deduction is sought and
that it became worthless during that year. Estate of Mann v.
United States, 731 F.2d 267, 275 (5th Cir. 1984); James A. Messer
Co. v. Commissioner, 57 T.C. 848, 861 (1972); Shipley v.
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