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undistributed long-term capital gains from RIC's shown on the
Forms 2439. See sec. 852(b)(3)(D). Instead, petitioner claimed
on Schedule D, Capital Gains and Losses, of each of her returns a
long-term capital loss of $3,000. According to petitioner's
testimony, the capital loss deductions were taken because her
insurance company, Prudential, did not pay an automobile
insurance claim she had with them.
Petitioner presented no evidence that the Juman professional
corporation was a RIC as described in section 851(a) and (b). By
definition a RIC is a domestic corporation. See sec. 851(a). It
is clear that Amnesty could not be a RIC because it is not a
domestic corporation. Petitioner was not a shareholder of Juman
or of Amnesty. Petitioner has not shown that either of the
purported RIC's actually experienced any undistributed long-term
capital gains or paid any tax on such gains. From petitioner's
testimony it appears that Juman is a law firm that once briefly
employed her and Amnesty International is the name petitioner
uses when involved in matters related to her automobile accident.
Neither petitioner nor Amnesty is entitled to credits for tax
paid on undistributed long-term capital gains from RIC's.
Petitioner presented no documentary evidence or any
fathomable testimonial evidence on any other issue in the case.
The court has no evidence on which to base a finding that any of
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