Haury v. Comr., T.C. Memo. 2012-215

(petitioner developed software and licensed it to two companies that he had significant ownership interests in; companies developed cash-flow problems and petitioner transferred funds from his IRA to the companies; ultimately, petitioner demanded repayment, but companies could not repay and petitioner reported a bad debt deduction; court held that loan non-business bad debt because petitioner interested in protecting investment in companies rather than protect salary).