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          the loans were made; (3) the adequacy and nature of the                     
          taxpayer’s records; (4) whether the loan activities were kept               
          separate and apart from the taxpayer’s other activities; (5)                
          whether the taxpayer sought out the lending business; and (6) the           
          amount of time and effort expended in the lending activity and              
          the relationship between the taxpayer and his debtors.  United              
          States v. Henderson, 375 F.2d 36, 41 (5th Cir. 1967); Serot v.              
          Commissioner, T.C. Memo. 1994-532, affd. without published                  
          opinion 74 F.3d 1227 (3d Cir. 1995).                                        
               Petitioner argues that he was in the trade or business of              
          “making loans and guaranties”; he relies on the following summary           
          of guaranties and loans that petitioner claims he made:                     
                              Guaranties petitioner made                              
               Year      Debtor        Amount of guaranties Guaranty fee              
               1984      IBC       $9,000,000               $90,000                   
          1987         IBC              15,000,000          150,000                   
               1988         IBC         17,500,000          175,000                   
               1989      IBC Amusement                                                
                         Rides, Inc.    1,500,000           150,000                   
               1990         IBC         8,500,000           85,000                    
               Total               51,500,000               650,000                   
                              Loans petitioner made                                   
               Year      Debtor    Amount of loans     Number of loans                
          1979-86      IBC         $397,738                 125                       
          1989           WMG       3,000,000                1                         
               1989      WMG          1696,456              23                        
               1990      WMG       643,646                  61                        
               1991      WMG       236,450                  25                        
               1992      WMG           210,560              5                         
               Total                34,989,850              240                       
          1Respondent points out that this amount includes $90,843.21, which petitioner
          paid to Natwest in 1989, in respect of his personal obligation to Natwest.  
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