O'CONNOR, J.
The taxpayer is in the business of owning and operating commercial real estate. He was also the president and sole shareholder of Eleganza, Inc., a mail order business. Eleganza, Inc., became insolvent in 1975, and the taxpayer was required to pay $170,000 pursuant to his personal guaranty of a debt owed by Eleganza, Inc. Insolvency rendered the taxpayer's claim against Eleganza, Inc., worthless. The taxpayer sold a parcel of land that he
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