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petitioner’s recap states as follows: “Short Term Capital Loss -
Worthlessness of Shareholders Loans - EFN ($33,003.00)”.
Petitioner makes no arguments in his reply brief regarding this
issue. We conclude that petitioner’s bad debt loss in 1991 is
$33,003. See Money v. Commissioner, 89 T.C. 46, 48 (1987).
IV. Issue 4. 1993 Net Operating Loss
A. Background
On Schedule E, Supplemental Income and Loss, of petitioner’s
original 1990 Federal income tax return, he reported nonpassive
losses from Schedule K-1, Partner’s Share of Income, Credits,
Deductions, Etc., of $130,722 and passive and nonpassive income
from Schedule K-1 of $52,633. This resulted in a loss on
Schedule E of $78,089. On Schedule 1, petitioner reported that
$78,386 of the $130,722 nonpassive losses was from Farm & Grove.
On page 1 of petitioner’s 1990 Federal income tax return, he
reported a negative adjusted gross income of $77,183, which
consisted of the $78,089 loss from Schedule E, taxable interest
income of $844.05, and dividend income of $61.08.
On petitioner’s amended 1990 return, he increased the
reported loss from Farm & Grove by $4,506 to $82,892 and reported
additional income of $32,172 from the 100-lot partnership.
On Schedule E of petitioner’s 1992 Federal income tax
return, he reported nonpassive losses from Schedule K-1 of
$122,867 and passive and nonpassive income from Schedule K-1 of
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