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1970); Feinstein v. Commissioner, 24 T.C. 656, 657-659 (1955);
see also Kitch v. Commissioner, 104 T.C. 1, 5 (1995) (fact that a
case is fully stipulated does not lessen the burden of proof),
affd. 103 F.3d 104 (10th Cir. 1996). The taxpayer, to establish
worthlessness, must prove not only current balance sheet
insolvency, but also the absence of any reasonable expectation
that the assets of the corporation will exceed its liabilities in
the future. See Steadman v. Commissioner, supra at 376-377.
Whether stock is worthless is a factual determination, as is the
determination of the year in which stock becomes worthless. See
Boehm v. Commissioner, 326 U.S. 287, 293 (1945); Finney v.
Commissioner, 253 F.2d 639, 642 (9th Cir. 1958), affg. in part
and revg. in part T.C. Memo. 1956-247; Austin Co. v.
Commissioner, 71 T.C. 955, 969 (1979).
We hold that petitioners have failed to meet their burden of
proving that Mr. Murray’s Poinciana stock became worthless in
1993. Petitioners rely primarily on their bald assertions on
brief to the effect that the stock became worthless at the time
of the foreclosure. These assertions do not persuade us that the
stock became worthless in 1993. See Aagaard v. Commissioner, 56
T.C. 191, 209 (1971); see also Hoover v. Commissioner, 32 T.C.
618 (1959) (a taxpayer’s belief that the cost of stock cannot be
recovered is not sufficient to establish that the stock is
worthless). Nor are we persuaded by the mere fact that Poinciana
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