(petitioner loaned $200,000 in 1988 to distant relative and received promissory note in return; monthly payments were not initially made until 1990 and only partial interest payments were made from 1990-2000; last payment of any kind made in 2003; borrower died in 2004 and efforts to collect from decedent’s sons failed; petitioner deducted loan as non-business bad debt on 2006 return; court denied deduction because debt became worthless before 2006; no formal claim made in decedent’s estate or that decedent’s sons legally obligated to pay loan; court determined that petitioner’s decision not to enforce debt was for personal reasons).