Billie and Florence Lykins - Page 15

               Accordingly, we conclude that petitioner's dominant                    
          motivation in making the loan to Tag Coal was to protect J & M's            
          equipment and ultimately petitioner's ability to lease such                 
          equipment to third parties.  We therefore hold that the debt owed           
          to petitioner by Tag Coal is appropriately characterized as a               
          business bad debt and is deductible by petitioners as such.                 
               In order to reflect our disposition of the disputed issues,            
          as well as the parties' concessions,                                        

                                                  Decision will be entered            
                                             under Rule 155.                          

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Last modified: May 25, 2011