- 4 - 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 closed. 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 petitionerPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011