- 21 - General ledgers and income tax returns of Blackland for the relevant years are not in evidence, which would reflect the ledger and tax return treatment by Blackland of the funds received from petitioner and the details of Blackland’s March 1996 $600,000 transaction with petitioner. Petitioner, who has the burden of proof, has failed to establish that a genuine debtor-creditor relationship existed between Blackland and himself with regard to the funds in question and that the purported loans constituted valid debt. Further, and in the alternative, we conclude that the evidence does not establish that the purported loans to Blackland became worthless by the end of 1995, the year for which the bad debt deduction is claimed. As late as December 31, 1995, petitioner continued to transfer funds to Blackland, and in 1996 Blackland continued to transfer funds to petitioner. In December of 1995, Blackland had just begun settlement negotiations with the tenant farmers which negotiations were not completed until April of 1996. Blackland itself did not claim a bad debt deduction with regard to the loans it made to the tenant farmers until its 1996 Federal income tax return was filed. Had Blackland in 1996 recovered more funds from the farmers, those funds would have been available to transfer additional funds backPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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