- 8 - There is no standard test or formula for determining worthlessness, and the determination depends upon the particular facts and circumstances of the case. Lucas v. American Code Co., 280 U.S. 445, 449 (1930); Crown v. Commissioner, supra. A taxpayer must usually show identifiable events to prove worthlessness in the year claimed. United States v. S.S. White Dental Manufacturing Co., 274 U.S. 398 (1927); Crown v. Commissioner, supra; Dallmeyer v. Commissioner, 14 T.C. 1282, 1291-1292 (1950). Debts are wholly worthless when the taxpayer had no reasonable expectation of repayment. Crown v. Commissioner, supra. After carefully considering all the facts, we conclude petitioners have failed to prove that the $491,054 debt petitioner claimed became wholly worthless in 1995. We therefore sustain respondent’s determination. Whether Job Termination Can Render a Debt Worthless Petitioner argues that firing Evans was the “identifiable event” that rendered the loan worthless in 1995. We disagree. Once Evans was fired from the Clinic, he found similar employment at another medical clinic. There is nothing in the record to show that repayment was conditioned upon Evans’ continued employment with the Clinic. In addition, petitioner has not pointed us to, nor have we found, any case in which terminating a debtor’s employment alone renders a debt worthless. In fact, there is a case that indicates just the opposite. An insurance company was denied bad debt deductions for unpaidPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011