- 4 -
Peach Tree Property
Beginning in 1991, petitioner rented out real property he
owned in Penryn, California (Peach Tree Property). In 1997
petitioner sold the Peach Tree Property for $235,000.
Dejanu Loan
In mid-1994, petitioner made two loans to a friend of his by
the name of Peter Dejanu (Dejanu), which loans totaled $15,000.
The loans were to be repaid by Dejanu with interest 30 days from
the date each loan was made. Dejanu did not repay the loans.
Petitioner attempted to obtain repayment of the loans from Dejanu
on approximately a weekly or biweekly basis from the due date in
1994 until some time in 1997.
In 1997, petitioner discovered that Dejanu was essentially
insolvent and was seeking funds from other individuals. After
discovery of Dejanu’s desperate financial situation, and his
unsuccessful collection efforts and the length of time his loans
to Dejanu had been in default, petitioner concluded that the
Dejanu loans were uncollectible, and petitioner ceased collection
activities. Petitioner did not recover any principal or interest
on the Dejanu loans.
Tax Return and Respondent’s Audit
On June 20, 1999, petitioner untimely filed with respondent
his 1997 individual Federal income tax return, on which
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011