guaranty.
A much trickier question is whether the debt the obligation owed by Larry to Jack was worthless in 1997. Courts have held that worthlessness is evidenced by the happening of certain events or the existence of certain facts that are ascertainable at a fixed period in time. In addition, worthlessness has been defined as a lack of potential values as well as a lack of current value. Higginbotham-Bailey-Logan Co. v. Comm., 8 B.T.A. 566 (1927); LeLandais v. Comm., T.C. Memo 1976-345. However, a debt is not worthless just because it is of doubtful value or difficult to collect. White v. Comm., T.C. Memo 1971-13. Rather, the question of primary importance is whether the taxpayer, in the exercise of sound business judgment, based upon as complete information was reasonably obtainable, could have determined that the debt in fact had become worthless. Minneapolis, St. Paul & S.S.M.R. Co. v. U.S., 64-1 U.S.T.C. ¶ 9213 (Ct. Cl. 1964); Portland Mfg. Co. V. Comm., 56 T.C. 58 (1971), aff'd 75-1 U.S.T.C. ¶ 9449 (9t
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