Vernon Miller - Page 15




                                               - 15 -                                                  
            legal expenditures that petitioner had paid as of the end of 1993                          
            were for the recovery of the principal of the Miller loan, and                             
            not for the recovery of interest thereunder.  On the record                                
            before us, we find that petitioner has failed to establish that                            
            the unrecovered portion of the Miller loan and the legal expendi-                          
            tures that he had paid as of the end of 1993 in connection with                            
            the recovery of that loan constitute under section 165(c) a loss                           
            that he incurred during 1993 (1) in a trade or business, (2) in a                          
            transaction entered into for profit, even though not connected                             
            with a trade or business, or (3) from fire, storm, shipwreck, or                           
            other casualty, or from theft.                                                             
                  To reflect the foregoing and the concession of petitioner,                           


                                                      Decision will be entered                         
                                                for respondent.                                        






















Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  

Last modified: May 25, 2011