Ahadpour v. Commissioner

MEMORANDUM *

The tax court did not err in determining that Treas. Reg. § 1.166-l(e) precludes Ahadpour from taking an $8 million deduction for bad debt in connection with the sale of his Iranian business.1 Ahadpour argues that Section 1.166 — 1(e) does not apply to individuals not subject to reporting requirements at the time of the taxable event and attempts to rely by analogy on a *321number of cases involving casualty war loss deductions. While these cases do not consider the prior tax treatment of assets on a foreign return, they illustrate that there is nothing remarkable about applying…