Thomas K. and Billie J. Scallen - Page 37




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          is no evidence that petitioner was to receive or expected to                
          receive any compensation as a result of the loan.                           
               Petitioner has not shown he was engaged in the trade or                
          business of making loans and guaranties at any relevant time in             
          the instant case.  Petitioner is not entitled to business bad               
          debt deductions for the amounts he lent to WMG.                             

                                                   An appropriate order              
          will be issued.                                                             

































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