Shaw v. Comr., T.C. Memo. 2013-170

(petitioner made advances during year in issue totaling $808,000 to family-owned business that petitioner was part owner of and later claimed bad debt deduction of $808,000 upon not being repaid; note called for 10 percent interest, but no collateral required and line of credit remained unsecured; petitioner failed to prove that advances were loans - no proof of repayment expectation or intent to enforce collection; no documentation of business's credit worthiness; petitioner's conduct inconsistent with outside third party lender; advances not worthless in 2009, the year deduction claimed; bankruptcy had not been filed even by mid-2011; no default occurred in 2009; deduction denied).