Although members of the taxpayer's family participated as lenders in at least 10 mortgage loan transactions, the taxpayer was involved as lender in only three of them (all of which went bad) Bonner TCJ. found (at p. 2156), after noting that "one of the factors which differentiates between loans made as simple investments of capital and loans made in the course of the business of a money lender is continuity" that:
"the activity involved in the making of the appellant's three loans is, in my view, so restricted in scope as to be insufficient to establish that the appellant's ordinary business included the lending of money."