- 11 - affg. T.C. Memo. 1978-274; Grant v. Commissioner, 84 T.C. 809, 820 (1985), affd. without published opinion 800 F.2d 260 (4th Cir. 1986); Rink v. Commissioner, 51 T.C. 746, 753 (1969). Thus, a taxpayer is not entitled to a deduction for the imputed value of services which he has not been required to report as income. See Maniscalco v. Commissioner, supra at 7-8; Grant v. Commissioner, supra at 820; Rink v. Commissioner, supra at 753. Petitioners make no allegation that they reported the $920,000 of claimed losses on any of their Federal income tax returns, and they represented that they were cash basis taxpayers for the years in issue.9 Section 165 provides, in general, for the deductibility of losses sustained by the taxpayer. Section 166 provides, in general, for the deductibility of debt which becomes worthless during the taxable year. Under both provisions, the amount of the deduction is determined by reference to the adjusted basis provided in section 1011 for determining the loss from the sale or other disposition of the property. See secs. 165(b) and 166(b). The deduction of a bad debt or a loss from gross income 9In an exhibit attached to respondent’s motion for partial summary judgment, respondent asked petitioners whether they reported the sale of the on-farm energy plant to Laurington Corp. on any of their Federal income tax returns. Petitioners replied that “I don’t believe it was because we were on a cash basis and no cash was received.” Petitioners have not disputed any of the exhibits attached to respondent’s motion and have referenced the exhibits in their arguments opposing respondent’s motion for partial summary judgment.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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