Ahadpour

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 *321 number 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 Internal Revenue Code rules to calculate basis for a current deduction on a United States return, even though the asset was acquired at a time the individual seeking the deduction was not a United States resident. See, e.g., Gutwirth v. Commissioner, 40 T.C. 666, 678-79 , 1963 WL 1399 (1963) (applying I.R.C. depreciation rules to foreign asset); see also Antuna v. Commissioner, T.C. Memo.1970-290 (applying Treas. Reg. § 1.661 -l(e) to disallow bad debt deduction for unpaid commissions incurred prior to United States residency).

We are not persuaded by Ahadpour’s argument that Section…