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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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