Kernrechtsfrage
Whether the alleged losses from exchange guarantees were deductible business losses or non-deductible private losses
Extrahierter Entscheid
The taxpayers failed to prove a binding business arrangement or commercial character of the exchange guarantees; the loss was not deductible.
Extrahierte Begründung
The cantonal court could rely on the lack of enforceable agreement, absence of payments or accounting records, the taxpayer's role as sole director, and the friendship-based nature of the guarantees. The factual findings were not arbitrary.