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QUESTION

John was the chief executive officer, a shareholder that own 60% of outstanding stock of Maze, Inc. during 2011.

John was the chief executive officer, a shareholder that own 60% of outstanding stock of Maze, Inc. during 2011. In 2008, John and Maze borrowed $100,000 loan from United National Bank as co- borrower. The loan was secured by John’s personal residence. John wants to get bad debt deduction for the loan payment because he repaid the loan his personal money in 2011. However when Mazes Form 1120 tax returns, they report no loans form shareholders. Partial list of research aids:US v. Generes, 405 US 93 (1972)Dale H. Sundby, T.C.Memo. 2003-204Arrigoni v. Comm., 73 T.C. 792 (1980)Estate of Herbert M. Rapoport, T.C.Memo. 1982-584Clifford L. Brody and Barbara J. DeClerk, T.C. Summary Opinion, 2004-149

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