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issue, and not until 1995 did the court enter judgment largely in
favor of petitioner. It seems unlikely that a reasonable
business person would spend substantial time and money to collect
a wholly worthless debt. Petitioner still receives payments,
albeit nominal in amount, on the Aloi judgment.
The Tooke Loans
With respect to petitioner's $30,000 guarantee of the Tooke
floor-planning credit line, and its attendant litigation, the
parties stipulated evidence of a settlement recommendation by
petitioner's attorney in June of 1991. The recommended
settlement required that petitioner acquiesce in the liquidation
of his collateral by the creditor. If the settlement was entered
into in 1991, and there is no evidence to show otherwise,
petitioner's debt became worthless in 1991. See sec. 1.166-9(a),
(d), Income Tax Regs. There was no right of subrogation in the
agreement between petitioner and Mr. Tooke that would delay the
determination of the year of worthlessness. See sec. 1.166-
9(e)(2), Income Tax Regs.
As to the 10 used-car-buyers' notes petitioner purchased
from Mr. Tooke, all the borrowers defaulted in 1989. Of the nine
for which he received title, petitioner retains the title to all
except one which he exchanged for a payment of $800 on April 27,
1992. Petitioner testified that it was not clear when some of
the notes became worthless. Petitioner had not obtained credit
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