United States Tax Court May 23, 1977, Docket No. 4733-75. (Eberhart v. Commissioner)

RAY EBERHART and PEGGY EBERHART, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Eberhart v. Commissioner Docket No. 4733-75. United States Tax Court T.C. Memo 1977-155; 1977 Tax Ct. Memo LEXIS 289; 36 T.C.M. (CCH) 660; T.C.M. (RIA) 770155; May 23, 1977, Filed *289 Petitioner had made 60 loans to various individuals and corporations over a 26-year period.