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Some of the factors which have been considered in
determining whether a taxpayer is engaged in the trade or
business of lending money include: The total number of loans
made; the time period over which the loans were made; the
adequacy and nature of the taxpayer's records; whether the loan
activities were kept separate and apart from the taxpayer's other
activities; and whether the taxpayer actively sought out lending
business. Ruppel v. Commissioner, T.C. Memo. 1987-248; McCrackin
v. Commissioner, T.C. Memo. 1984-293. We have also considered
the amount of time and effort expended in pursuit of the lending
activity and the relationship between the taxpayer and his
debtors. See Zivnuska v. Commissioner, 33 T.C. 226, 237-238
(1959); Fuller v. Commissioner, 21 T.C. 407, 412-413 (1953); see
also United States v. Henderson, 375 F.2d 36, 41 (5th Cir. 1967).
The Court finds that the factors in the record are
indicative of petitioner's being in the trade or business of
lending money in the years 1992 through 1994. See Serot v.
Commissioner, T.C. Memo. 1994-532, affd. without published
opinion 74 F.3d 1227 (3d Cir. 1995); Ruppel v. Commissioner,
supra. The Court therefore concludes that petitioner was in the
trade or business of lending money during the years at issue.
Petitioner is entitled to deduct business expenses on
Schedule C for the years 1992 through 1994 associated with his
money-lending business. If petitioner shows all the necessary
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