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for repayments, id.; (4) whether any security or collateral is
requested, Zimmerman v. United States, 318 F.2d 611, 613 (9th
Cir. 1963); (5) whether a demand for repayment has been made,
Montgomery v. United States, 87 Ct. Cl. 218, 23 F. Supp. 130
(1938); (6) whether any repayments have been made, Estate of Ames
v. Commissioner, a Memorandum Opinion of this Court dated Feb. 7,
1946; and (7) whether the borrower was solvent at the time of the
loan, Jewell Ridge Coal Corp. v. Commissioner, 318 F.2d 695, 699
(4th Cir. 1963), affg. T.C. Memo. 1962-194. For reasons set
forth above, the belatedly tendered notes were not reliable and
were not received in evidence. There was no evidence offered
with respect to the other factors.
Respondent argues, and we agree, that it appears from
petitioner’s testimony that the funds advanced as claimed by
petitioner were investments, not bona fide loans. There was no
apparent investigation or evidence of the financial solvency of
the alleged borrowers or evidence that they intended to repay
petitioner for the advances. In addition, petitioner presented
no objective evidence that the advances became worthless by the
end of 1999. It is improbable that he would have continued to
lend money through December 1999 and that the advances
simultaneously became worthless.
Petitioner did not disclose to respondent or present any
information concerning the purported loans until the day of
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