Lawrence Robert Clifton-Bligh - Page 4

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               approximately $125,000 in SJC; and in 1989 SJC filed                   
               for bankruptcy;                                                        
                    (2) he suffered losses as a Lloyd’s underwriter;                  
                    (3) in 1991 he invested $25,000 in a company                      
               called Marisco International Trading (Marisco) in which                
               Al Marisco was the principal; and Marisco “wound up” in                
               1992 (but petitioner testified that he was not able to                 
               verify this);                                                          
                    (4) in 1984 he invested $5,000 in a company called                
               C Films; C Films “wound up” years later; and he lost                   
               his entire investment in C Films; and                                  
                    (5) he advanced approximately $85,000 to a company                
               his wife founded and ran called Stamp, Stamp, Stamp                    
               (SSS); SSS closed in 1993; and he lost $50,000 when SSS                
               We review the economic realities of transactions between               
          family members--i.e., the SSS transactions--with heightened                 
          scrutiny.  Estate of Reynolds v. Commissioner, 55 T.C. 172, 201             
          (1970).  Petitioner relies on his own testimony to substantiate             
          his losses from SJC, Lloyd’s, Marisco, C Films, and SSS.  The               
          Court is not required to accept petitioner’s unsubstantiated                
          testimony.  Wood v. Commissioner, 338 F.2d 602, 605 (9th Cir.               
          1964), affg. 41 T.C. 593 (1964).                                            
               Petitioner did not present any evidence regarding when C               
          Films supposedly wound up or when he “lost” this investment.                
               Petitioner submitted 6 pages of a 13-page fax containing a             
          settlement offer and “Finality Statement - August 1996” regarding           
          Lloyd’s.  The document does not establish that petitioner                   

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