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all in the year 1991. Petitioner retained a lien interest of
unknown value. The Brown note was made in 1991 and renewed in
1992. The next relevant event was the filing of a petition in
bankruptcy by Mr. Brown in 1996. The Johnson note was the
subject of a foreclosure suit resulting in a judgment conveying
to petitioner the deed of trust property of unknown value. At
some later unknown date, Mr. Johnson filed for bankruptcy.
Petitioner obtained title to property of unknown value securing
the Norman/Beard loan in 1988 and then leased the property to
various tenants until 1998. The Fuller property, of unknown
worth, foreclosed on by petitioner in 1993, was sold by him in
1999 for an unknown amount. The maker of the ILN notes filed for
bankruptcy in 1991, and the property securing petitioner's notes
was insufficient to pay secured creditors senior to petitioner.
Without evidence of the financial situation of the debtors
and the value of collateral petitioner obtained, we are unable to
determine that in 1992 through 1994 the subject loans became
totally lacking in value and lacked any potential for future
collectibility. See Pierson v. Commissioner, 27 T.C. 330, 338-
339 (1956), affd. 253 F.2d 928 (3d Cir. 1958); Dean v.
Commissioner, T.C. Memo. 1970-75. The evidence is insufficient
to show that the real estate loans became worthless in the years
at issue.
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