- 19 -
Regs. Petitioner contends that he had more than $3 million in
bad debts in 1988 from the lending activity.
Petitioner contends that he is entitled to carry back a net
operating loss of $1,006,000 from 1988 to 1987 and to carry
forward a net operating loss of $1,594,000 from 1988 to 1989 and
later years. We disagree. Petitioner’s vague testimony is the
only evidence supporting his claim.
Petitioner attached to his answering brief a document which
states that a judgment was entered on October 9, 1992, in the
Supreme Court of the State of New York, County of Kings, in favor
of Ruth Wapnick against the Estate of Joseph Elashvili in the
amount of $153,015. Petitioner contends that this document shows
that loans to the Estate of Joseph Elashvili were worthless.
This document was not offered or admitted into evidence. Even if
it had been admitted, there is no evidence that the debt
described in the document became worthless during the years in
issue, that the judgment is uncollectible, or that the judgment
related to a loan made by petitioner which is at issue in this
case.
Petitioner lent $40,000 to Alberto, Inc., and contends that
Alberto, Inc., repaid only $11,000. Petitioner contends that his
loan to Alberto, Inc., resulted in a $29,000 loss. We are not
convinced that petitioner lost $29,000 as a result of his loan to
Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: May 25, 2011