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On the record before us, we find that petitioner has failed
to prove that he is entitled for 1989 to treat as a nonbusiness
bad debt the interest on the October 5 and the October 7 notes.
Claimed Nonbusiness Bad Debt of Mr. McWilliams
Petitioner contends that the aggregate amount of principal
and interest on Mr. McWilliams' note is a bona fide debt that
became worthless during 1989. Petitioner introduced into evi-
dence a note signed by Mr. McWilliams on December 15, 1987, which
stated that Mr. McWilliams was to repay Nathanael Roman $4,500 at
an annual percentage interest rate of 12 percent in monthly
installments of principal and interest totaling $275. In addi-
tion, petitioner testified that: (1) He lent Mr. McWilliams the
amount represented by Mr. McWilliams' note, (2) during 1989 Mr.
McWilliams was unable to pay certain creditors, and (3) he
determined that Mr. McWilliams was unable to pay the aggregate
amount of the principal and interest on Mr. McWilliams' note.
Based on petitioner's documentary and testimonial evidence
regarding Mr. McWilliams' note, we find that the aggregate amount
of the principal and interest on Mr. McWilliams' note is a bona
fide debt within the meaning of section 166. We must now deter-
mine whether petitioner has shown that that debt became worthless
during 1989. The only evidence presented at trial with respect
to the worthlessness of Mr. McWilliams' note was petitioner's
testimony that during 1989 he determined that Mr. McWilliams was
unable to pay certain creditors. More than petitioner's belief
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