Willie Waylon is a famous country-and-western singer. As an investment, Willie started a chain of barbecue restaurants called Willie’s Wonderful Ribs.

Willie’s friends and associates invested $500,000 in this venture. The restaurant chain failed, and the investors lost all their money. Because of his visibility and status in the entertainment community, Willie felt that he personally had to make good on the losses suffered by the investors, to protect his singing and business reputation. Consequently, he personally paid $500,000 to reimburse the investors for their losses. What are Willie’s tax consequences (if any) from the reimbursement?
Partial list of research material: §162 and Lohrke, 48 T.C. 679.