Maurice E. John, Jr. and Jan E. John - Page 8

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               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 unpaid              





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