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promoter. It appears to us that, in making the advances,
petitioner’s motivation was to protect his reputation as an
investor. Petitioner also contends that he made advances to
Color Trick in an effort to protect the investments of the other
physicians who had loaned money to Color Trick. Advancing money
to a corporation to protect the investments of others, however,
is an indication that the taxpayer is not a promoter. United
States v. Clark, supra at 896.
Petitioner also contends that his advances and loans to
Color Trick exceeded his initial investment in its stock by 60
times and that this circumstance indicates the lack of an
investment motive for the loans and advances. We do not consider
the circumstance pointed to by petitioner indicative of the lack
of an investment motive given that petitioner (1) acquired
additional stock in Color Trick during 1988 and 1989, (2) held 60
percent of its stock by the end of 1989 and (3) was not entitled
to compensation for his services to Color Trick. It seems quite
plausible to us that petitioner’s loans and advances were made to
protect his increasing and substantial equity stake in the
corporation.
Based on our consideration of the entire record in the
instant case, we hold that petitioner’s loans and advances to
Color Trick, which became worthless in 1989, are nonbusiness bad
debts. Whipple v. Commissioner, 373 U.S. at 203-204; United
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