Into the Owens, T.C. Memo. 2017 – 157 , the fresh Tax Legal stored one to one are eligible to a great bad financial obligation deduction having fund he made to a corporate that after that ran broke as (1) anyone is actually active in the organization out of credit currency while in the recent years involved; (2) brand new loans were bona fidedebt (despite in some instances getting built to secure the troubled providers afloat); and (3) your debt turned into meaningless in the year claimed, whilst the borrower failed to seek bankruptcy relief up until the following year.
Owens’s financing company: William Owens try the majority shareholder away from Owens Economic Classification Inc. (OFG), a commercial lending company started of the their father, along with offered as the OFG’s chairman for 2 decades. OFG will get much of their organization from the recommendations, also it and you can Owens liked a good reputation in the business. According to Owens’s prices, during the their time in the OFG, the firm made throughout the $dos.5 million within the funds (regarding the $225 million at which they needed to foreclose for the). Including his financing as a result of OFG, while the no less than 1986, Owens got made many fund out-of his very own property, often due to their own trust.