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Loan advanced in the ordinary course of business may generate an allowable revenue loss when waived under a settlement, provided it formed part of the taxpayer's commercial activities and neither acquired a capital asset nor represented a long-term capital investment. Financial participation through a shareholder-financier arrangement, repayable from business surplus, can retain its business character. The waiver was treated as incidental to business, distinguishable from an advance made to acquire immovable property, and the deduction was allowed.
Loan advanced in the ordinary course of business may generate an allowable revenue loss when waived under a settlement, provided it formed part of the taxpayer's commercial activities and neither acquired a capital asset nor represented a long-term capital investment. Financial participation through a shareholder-financier arrangement, repayable from business surplus, can retain its business character. The waiver was treated as incidental to business, distinguishable from an advance made to acquire immovable property, and the deduction was allowed.
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