During 2016, John was the chief executive officer and a shareholder of Maze, Inc. He owned 60% of the outstanding stock of Maze. In 2013, John and Maze, as co-borrowers, obtained a $100,000 loan from United National Bank. This loan was secured by John's personal residence. Although Maze was listed as a co-borrower, John repaid the loan in full in 2016. On Maze's Form 1120 tax returns, no loans from shareholders were reported. Discuss whether John is entitled to a bad debt deduction for the amount of the payment on the loan. Partial list of research aids:
U.S. v. Generes, 405 U.S. 93 (1972).
Dale H. Sundby, T.C.Memo. 2003-204.
Arrigoni v. Comm., 73 T.C. 792 (1980).
Estate of Herbert M. Rapoport, T.C.Memo. 1982-584.
Clifford L. Brody and Barbara J. DeClerk, T.C. Summary Opinion, 2004-149.