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year in which there is no reasonable prospect of recovering the
loan. See Aston v. Commissioner, supra; Crown v. Commissioner,
77 T.C. 582, 598 (1981). The determination of worthlessness must
be fixed by identifiable events which form the basis of reason-
able grounds for abandoning any hope of recovery. See Aston v.
Commissioner, supra; Crown v. Commissioner, supra.
Based on our examination of the entire record before us, we
find that petitioner has failed to establish that the $2,641 of
unrecovered principal of the Miller loan became worthless during
1993. We find on that record that petitioner has failed to show
any identifiable events which could have formed the basis of
reasonable grounds for abandoning any hope of recovering that
amount. In fact, the record establishes that petitioner contin-
ued to prosecute the Miller loan lawsuit after 1993 in order to
recover the balance due on the Miller loan and the legal expendi-
tures that he had incurred in connection with recovering the
Miller loan. As a result of that lawsuit, petitioner was enti-
tled to recover the entire $75,000 principal of the Miller loan
(with offsets of $72,358.88 attributable to the amount of that
principal that he recovered as of 1991), and on or about March 3,
1998, he was awarded $208,206 in attorney’s fees incurred in
connection with his litigation relating to that loan. On the
record before us, we hold that petitioner is not entitled to
nonbusiness bad debt treatment under section 166(d) with respect
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