Thomas A. and Maria M. Hagman - Page 8




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          transaction entered into for profit’ surely means something more             
          than the mere casual preliminary investigation of a prospective              
          business or investment.”  Although petitioner expended capital,              
          he has failed to demonstrate what steps, if any, were taken                  
          beyond a preliminary investigation.  Petitioner’s testimony on               
          this subject was vague and, to some extent, incomprehensible.                
          Accordingly, petitioners are not entitled to a deduction under               
          section 165(c)(2).  See Brown v. Commissioner, 40 T.C. 861, 869-             
          870 (1963); see also Frank v. Commissioner, supra.                           
          III.  Bad Debt Losses                                                        
                                   FINDINGS OF FACT                                    
               In the early 1980’s, petitioner formed a partnership with               
          Albert J. Schara (Mr. Schara) for the purpose of buying and                  
          selling real estate.  Over the course of their partnership,                  
          petitioner made several loans to Mr. Schara or to partnerships               
          controlled by him.  When the partnership dissolved in 1988, Mr.              
          Schara had loans outstanding to petitioner totaling $147,000.                
          These loans were represented by three separate notes.  One note              
          was given in exchange for two checks (a $50,000 check dated March            
          23, 1984, and a $5,000 check dated November 2, 1984) made payable            
          to Schara Development Co., although Mr. Schara was personally                
          liable for the entire debt.  Another note was in the principal               
          amount of $136,024 and dated February 4, 1983.  This note                    
          represented several separate payments from petitioner to T. A.               
          Investments, a partnership that was controlled by Mr. Schara.                
          Two payments totaling $56,000 were made on this note, reducing               


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