OPINION
CHAMBERS, Circuit Judge:
The issue in this case is whether payments of approximately $300,000 made by taxpayer M. Seth Horne as indemnitor in connection with obligations of corporations in which he owned a substantial interest are deductible as ordinary losses. Horne was the principal partner in a real estate development firm which owned all the outstanding shares of James Stewart and Co., Inc. (COINC). COINC had two wholly-owned subsidiaries, James...
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