§1662

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

WHERRY, Judge: In 2003 John Rogers developed, marketed, and sold investments, which also allegedly provided potential tax shelter, whereby investors in a.partnership structure could claim partially worthless bad debt deductions under section 1662 on certain distressed assets formerly owned by a Brazilian retailer.

535, 547 (1988),("If Congress ha d intended : instead that primary alcoholism not be deemed `willful misconduct' for purposes of § 1662(a)(.1),, as it had been deemed 23I'f an S co'rporation's S election is inadvertently terminated (for example, because stock is issued to an ineligible shareholder), the S corporation can seek a PLR deeming the' termination inadvertent and permitting the S corporation to retain its S corporation status .

535, 547 (1988) (“If Congress had intended instead that primary alcoholism not be deemed ‘willful misconduct’ for purposes of § 1662(a)(1), as it had been deemed for purposes of other veterans’ benefits statutes, Congress most certainly would have said so.”); Helvering v.