Allen C. Chamberlin and Martha L. Chamberlin - Page 12

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          minimal documents and testimony are sufficient to substantiate              
          the amount of loss with respect to Pharmacare.                              
               Petitioners also claim that they are entitled to recognize             
          losses from petitioner’s contributions to The Chamberlin Corp.              
          and Chamberlin Parenteral.  To substantiate their losses,                   
          petitioners have provided only a statement of net worth, prepared           
          in 1982, that showed that petitioners’ net worth was $6,032,052.            
          They argue that their net worth fell to zero in 1985 as a result            
          of The Chamberlin Corp. failure, and, therefore, they should be             
          entitled to a loss of $6,032,052.  Such a statement,                        
          uncorroborated by receipts, expenses, or other documentation that           
          reflects how assets were lost or disposed of, is insufficient for           
          determining the amount of losses sustained by petitioners.  See             
          Henry Schwartz Corp. v. Commissioner, 60 T.C. 728, 745-746                  
          (1973).  Thus, where petitioners have failed to provide any                 
          documentation to substantiate their loss, they have failed to               
          carry their burden of proving entitlement to deductions.                    
               Petitioners have provided documentation relating to a loan             
          that was made from a third party to petitioner personally and               
          loans that were made to The Chamberlin Corp., which were secured            
          and satisfied by personal property of petitioner.  First,                   
          petitioners argue that they are entitled to recognize $1,750,000            
          of loss stemming from a personal loan from Freedom Federal.                 

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