Henry A. Julicher - Page 16




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               In the notice of deficiency, respondent determined that                
          petitioner was not entitled to the claimed bad debt deduction               
          because he did not (1) establish a business purpose for the loss,           
          (2) show that the loss resulted from a bad debt and in particular           
          his bad debt, and (3) show that all reasonable steps were taken             
          to collect the debt.                                                        
          Bad Debt Deduction (Attieh Bros.)                                           
               In 1987 Julicher Sports was engaged by Attieh Bros. Co.                
          (Attieh Bros.), a family-owned business in Amman, Jordan, to                
          install the rink and other flooring materials for a skating rink            
          called the Skating Palace in Amman.  Attieh Bros. paid Julicher             
          Sports approximately $150,000 for the installation.  Petitioner             
          developed a close relationship with the Attieh family, in                   
          particular the brothers Thair and Nidal Attieh and their father             
          Raouf, and soon he was treated as if he were a member of the                
          family.  Raouf was a commercial attach� for the Jordanian                   
          Government with ties to the King of Jordan, and petitioner felt             
          he would be a valuable business contact in Jordan.                          
               On October 15, 1989, petitioner individually (i.e., not                
          Julicher Sports) and Attieh Bros. entered into a loan agreement             
          (First Loan Agreement) whereby petitioner would lend Attieh Bros.           
          $50,000 for a period of 5 years, to be repaid on or before                  
          October 15, 1994.  The money was to be used to add a franchise              
          restaurant to the Skating Palace.  The First Loan Agreement                 






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