- 7 - consolidation agreements with Aaland, to enforce collection of principal or interest that Aaland owed him. Viewed in its totality, the evidence in the record strongly suggests that petitioner’s purported loans to Aaland were actually in the nature of contributions of risk capital, in return for which petitioner received his 20-percent ownership interests in the corporations and by which he sought to protect his initial investment. Even assuming, however, that petitioner made bona fide loans to Aaland (and respondent has not argued otherwise), the record does not support a conclusion that petitioner had a separate business of lending money. Cf. Sales v. Commissioner, 37 T.C. 576 (1961); Rollins v. Commissioner, supra at 613; Estate of Palmer v. Commissioner, 17 T.C. 702 (1951). Accordingly, we sustain respondent's determination. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011