ABC Beverage Corp., f.k.a. Beverage America, Inc. - Page 16

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          Estate v. Commissioner, 216 F.2d 548, 549-50 (10th Cir. 1954),              
          affg. a Memorandum Opinion of this Court.                                   
               A taxpayer must generally show that identifiable events                
          occurred to render the debt worthless during the year in which              
          the taxpayer claimed the deduction.  Am. Offshore, Inc. v.                  
          Commissioner, 97 T.C. 579, 593 (1991).  Some objective factors              
          include declines in the value of property securing the debt, the            
          debtor’s earning capacity, events of default, the obligor’s                 
          refusal to pay, actions the obligee took to pursue collection,              
          subsequent dealings between the obligee and obligor, and the                
          debtor’s lack of assets.  Id. at 594.  No single factor is                  
          conclusive.  Id.                                                            
               Petitioner has shown that a series of specific, identifiable           
          events occurred during 1995 that, when taken together, rendered             
          the Properties loan worthless.  See id. at 593.  The most                   
          important of these events was the failure of the expected source            
          for repayment of the Properties loan, the G&K purchase.  Bottlers           
          anticipated that Properties would own the bottling facilities for           
          only a short time while G&K prepared to buy them.  When G&K could           
          no longer buy the facilities, the structure became untenable.               
               Another event that contributed to the worthlessness of the             
          Properties loan was that Bottlers opted not to pay Properties a             
          portion of the rent for valid business reasons, rendering it                
          impossible for Properties to pay Bottlers the principal on the              

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