Peter R. Geddis - Page 11

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               Additionally, petitioner has not established that Adrical’s            
          stock became worthless in 2000.  Petitioner has not offered any             
          evidence of the financial condition of Adrical in 2000.  There              
          simply is no evidence before us to support a finding that Adrical           
          had no liquidation value as of the end of 2000.                             
               Petitioner argues that the collapse of the Trieste project             
          is an identifiable event establishing that his investment in                
          Adrical had become worthless.  Petitioner, however, has not                 
          provided any evidence upon which we can determine that Adrical              
          was rendered worthless as a result of the failed Trieste project.           
          To the contrary, the registration of Adrical in 1999 to do                  
          business in California, after termination of the Trieste project,           
          indicates that management of Adrical anticipated activities in              
          California, which might have created future value for Adrical.              
               Based on petitioner’s testimony and the lack of evidence               
          herein, it has not been established that petitioner owned stock             
          in Adrical nor that Adrical stock became worthless in 2000.                 
               Petitioner has not established his entitlement to a section            
          165(g) capital loss in 2000 nor to the claimed capital loss                 
          carryforward in 2001 relating to Adrical.                                   
               Section 6651(a)(1) imposes an addition to tax for failure              
          to timely file a Federal income tax return, unless such failure             
          is due to reasonable cause and not to willful neglect.  Whether             
          reasonable cause exists to avoid imposition of the addition to              






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