- 19 - From the period the loan was made through the year in issue, the Attiehs advised petitioner that they intended to repay the loan. In a fax dated August 3, 1993, Thair informed petitioner that the Attiehs would begin paying $2,000 per month starting September 15, 1993, which was repeated in a fax dated August 19, 1993. During this period and through the time of trial, Thair and petitioner spoke often on the telephone. Petitioner remained in a close personal relationship with the Attiehs and occasionally sought further business dealings with them. The Skating Palace operated as a going concern until at least 1998. On the 1994 return, petitioner claimed a bad debt deduction of $70,000. 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. Joint Filing Status On their 1993 joint Federal income tax return, petitioner and his wife at the time Margit Julicher (Mrs. Julicher) selected “married filing joint” status. Petitioner, Mrs. Julicher, and Mr. Finder (as return preparer) signed the 1993 return. On the 1994 return, petitioner selected “married filing separate”Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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