Rather, we have simply asked whether the taxpayer was in the business of lending money, separate and distinct from any other gainful employment he or she may have had. See, e.g., Yaryan v. Commissioner, T.C. Memo. 2018-129, at *26 ("The parties agree that petitioners were not in a trade or business of lending funds."); Owens v. Commissioner, T.C. Memo. 2017-157, 114 T.C.M. (CCH) 188, 194 (inquiring whether the taxpayer's "personal lending was a trade or business"); Hatcher v. Commissioner, T.C. Memo. 2016-188, 112 T.C.M. (CCH) 415, 418 (finding that the taxpayer "was not engaged in the trade or business of lending money"), aff'd, 726 F. App'x 207 (5th Cir. 2018); Ruppel, 53 T.C.M. (CCH) at 832 (requiring the taxpayer to show "that he was in the trade or business of lending money"); Jessup v. Commissioner, T.C. Memo. 1977-289, 36 T.C.M. (CCH) 1145, 1150 (finding that the taxpayer was "in the business of making loans"). Respondent errs in relying on Rutter v. Commissioner, T.C. Memo. 2017-174, 114 T.C.M. (CCH) 282.