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Alberto, Inc., because petitioner’s only evidence supporting his
contention was his vague and uncorroborated testimony.
Petitioner contends that all of the bad debts from the
lending activity became totally worthless on December 15, 1988,
the date that the search warrant was executed and respondent took
all of his documents. We disagree. The mere fact that notes and
records which were evidence of the loans are not immediately
available to petitioner does not show that the loans were
worthless. See Perry v. United States, 51 AFTR 1234, 56-1 USTC
par. 9526 (S.D. Ga. 1956) (bad debt deduction not allowed in year
when lender’s business records and promissory notes were stolen).
Petitioner offered no evidence that the debts were worthless. We
are not convinced that execution of the search warrant caused all
of the debts to become worthless.
Petitioner contends that respondent’s agents told the
parties to whom he lent money to pay respondent instead of him.
There is no credible evidence to support that contention.
Petitioner contends that he received less income from loans
than respondent determined. However, petitioner’s vague and
uncorroborated testimony is less convincing than the documentary
and other evidence provided by respondent. We conclude that
petitioner had unreported income from loans to third parties of
$201,565 in 1985, $217,868 in 1986, and $341,324 in 1987.
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