- 29 - 1994 World Billfish Series, a segment of which was devoted to petitioners and their team, we conclude that petitioners participated in the tournaments for pleasure and recreation rather than the pursuit of business. This factor favors respondent. x. Conclusion On the basis of our careful review of the record and our evaluation of the nine aforementioned factors, we conclude that PMSI did not engage in the fishing activity with an actual and honest objective of making a profit. We sustain respondent’s determination. 2. Bad Debt Respondent determined that petitioners were not entitled to the claimed bad debt deduction. Petitioners assert that the dealership could deduct the $50,000 loan in 1995 as a bad debt because the loan was never repaid. Petitioners assert that the condominium when Mr. Peacock received it was worth less than the balance on the loan and that Mr. Peacock reported on his personal income tax return the proceeds which he received when he later sold the condominium. Section 166(a)(1) allows a deduction for any debt that becomes worthless within the taxable year. A nonbusiness bad debt is deductible only in the year it becomes totally worthless. A deduction is not allowed for partial worthlessness. Black v.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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