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petitioners are entitled to a loss under section 166(a) as
secured creditors on two residential properties upon the filing
of bankruptcy by the debtors.
Background
Some of the facts have been stipulated, and they are so
found. The first stipulation for trial, the stipulation of
settled issues, and the attached exhibits are incorporated by
this reference. Petitioners resided in Alexandria, Virginia, at
the time the petition was filed.
Intercontinental Trading Group (ITG)
In December 1992, Kenneth B. Satlin (hereinafter petitioner)
formed Intercontinental Trading Group, a Delaware corporation
(ITG).2 Petitioner was the senior corporate vice president of
ITG.3 Petitioner formed ITG for the purpose of purchasing used
automobiles in the United States with the intent of exporting
them to Venezuela. Petitioner intended to sell the vehicles to
the Venezuelan National Taxicab Association (VNTA).
Giancarlo Jasbon (Mr. Jasbon), petitioner’s business
associate in this venture, was ITG’s corporate president. Mr.
2 The record does not include any information regarding
ITG’s shareholders. While it seems likely that petitioner was a
shareholder of ITG, we are uncertain and make no findings in this
regard.
3 The record does not indicate whether petitioner was an
employee of ITG, or whether he received a salary from ITG.
Petitioner described the startup phase of ITG as one where he
“[spent his] entire six months exclusively on * * * [ITG]”.
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