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Petitioner alleges that this transfer gave him a stock interest
in Adrical.
Petitioner then claims that the $197,050 Wells Fargo loan
proceeds PGI received in 2000 were received by PGI only as his
nominee, and that the $197,050 was used by him to refinance, in
his own behalf, the previously mentioned 1997 $200,000 Wells
Fargo loan.
Based on his alleged stock interest in Adrical and Adrical’s
alleged worthlessness by the end of 2000, under section 165(g)
petitioner claims that in 2000 he incurred an approximate
$195,000 long-term capital loss relating to his claimed stock
interest in Adrical, giving rise to the $192,046 estimated long-
term capital loss carryover claimed on his and his wife’s 2001
Federal income tax return.
The evidence herein does not adequately substantiate that
petitioner made an investment of any kind in Adrical.
Petitioner did not produce adequate documentation or
witnesses to verify what, if anything, he invested in Adrical.
Some of the records petitioner did produce are inconsistent with
petitioner’s explanation for the transactions before us. Twice
in his testimony, petitioner acknowledged that he was unsure of
the accuracy of some of the records produced.
Various bank records were introduced into evidence, but they
were incomplete, lacking proper identification, and missing
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