Kenneth R. and Carol L. Bauer - Page 2

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          decision is whether petitioners are entitled to a nonbusiness               
          bad debt deduction pursuant to section 166.                                 
                                     Background                                       
               Some of the facts have been stipulated, and they are so                
          found.  The stipulation of facts and the attached exhibits are              
          incorporated herein by this reference.  Mr. Bauer resided in                
          Riverside, California, and Mrs. Bauer resided in Laughlin,                  
          Nevada, at the time they filed their petition.                              
               Mrs. Bauer is a real estate broker.  Mr. Bauer is a                    
          machinist.  During the year at issue, Mr. Bauer spent his                   
          weekends with Mrs. Bauer in Laughlin, Nevada, and in Bullhead               
          City, Arizona, a town located directly across the Colorado River            
          from Laughlin.                                                              
               Petitioners, but especially Mrs. Bauer, frequently dined at            
          a restaurant in Bullhead City named The Diamond Lil’s Drunken               
          Lobster (the Drunken Lobster).  The Drunken Lobster was an                  
          upscale restaurant specializing in steak and lobster that opened            
          in 1990.  The Drunken Lobster was owned and operated by father              
          and son, Salvatore and John Dubato (John) (collectively referred            
          to as the Dubatos), who also were petitioners’ personal friends.            
               During 1991, the Drunken Lobster was having financial                  
          problems.  The Dubatos approached petitioners for a loan, and               
          petitioners decided to advance them funds for use in their                  
          business.  Petitioners made a series of four interest-free loans            





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