Court denies bad-debt and NOL deductions after taxpayer fails to prove loans or timing

Fussell v. Commissioner, T.C. Memo. 2025-131, No. 9700-23. BL 454169.

The Tax Court upheld a 2018 deficiency and penalties after finding that the taxpayer never proved his claimed loans were real debt or that any loss could be carried back to 2018 through an NOL.

Holding

The court sustained the IRS deficiency and additions to tax. The taxpayer failed to establish a bona fide debt under §166, failed to prove worthlessness in…