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At the outset, we note that in order to constitute a
business bad debt, the dominant motive for the indebtedness must
relate to the taxpayer's trade or business. United States v.
Generes, 405 U.S. 93 (1972). Here petitioners stumble on the
definition of "trade or business". They stress several times on
brief that the dominant motive of the guarantee was "to preserve
his [petitioner Glenn Peterson's] employment and generate future
corporate profits." But employment and corporate profits are two
distinct concepts. Petitioners misunderstand that Glenn Peterson
wore two hats with respect to Dutchess--one as a shareholder-
investor, and one as an employee-officer. He had, however, for
purposes of section 166, only one trade or business--that of
being an employee or officer. Investing in a single enterprise
is not a trade or business. Whipple v. Commissioner, 373 U.S.
193 (1963). In this connection, we note that petitioners do not
contend that Glenn Peterson was in the trade or business of
financing corporations. See Raymond v. United States, 511 F.2d
185, 189 (6th Cir. 1975). In order to qualify for ordinary loss
treatment, petitioners would have to show that Glenn Peterson
originally made the guarantee to protect his "business" of being
an employee. Eisenberg v. Commissioner, 78 T.C. 336, 349 (1982);
Shinefeld v. Commissioner, 65 T.C. 1092, 1099 (1976).
Petitioners have conceded on brief that Glenn Peterson and
the other shareholders drew "nominal salaries (if any)". We
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