- 47 -
taxpayer was individually engaged in business. Id. at
1106. In view of the fact that the loans were made in
furtherance of that business and were proximately related
to the business activities of the partnership, we held that
the loans were business bad debts. Id. Similarly, in
Ward v. Commissioner, supra, we permitted a taxpayer who
had been a partner in a partnership to deduct, as ordinary
and necessary business expenses, payments in the nature of
pension payments made to a former employee of the partner-
ship. We noted that the taxpayer was engaged in a business
within the meaning of the predecessor of section 162(a)
"by reason of being a partner in a business". Id. at 343;
see also Flood v. United States, supra.
Finally, in Bauschard v. Commissioner, supra, the
issue presented to the Court was whether the taxpayer's
activities with respect to the purchase, development, and
sale of a tract of land constituted a trade or business.
The taxpayer contributed two-thirds of the purchase price
of an undeveloped tract of land which was placed in trust
for the taxpayer and the other buyer. Id. at 913. The
trust leased the property to a developer for a 5-year
term for the purpose of platting, subdividing, and improv-
ing the property, and it gave the developer an option of
purchasing any or all of the lots. Id. The developer
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