- 6 -
section 165 deductions. Id. We also note that petitioners do
not have a basis in the judgment. As a result, petitioners are
not entitled to a section 166 worthless debt deduction. See sec.
166(a) and (b); sec. 1.166-1(e), Income Tax Regs.
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
Decisions will be entered
for respondent.
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Last modified: May 25, 2011