Henry A. Julicher - Page 19




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               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”                  






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