For all that appears, this project involved an investment activity on Mr. McRae's part, not an activity having any relationship to his Schedule C2 business. See Wang v. Commissioner, T.C. Memo. 1998-389, 76 T.C.M. (CCH) 753, 757 (holding that a banker's insider trading was not directly or proximately related to his banking business but was sporadic activity arising from "a limited opportunistic transactional relationship"), aff'd, 35 F. App'x 643 (9th Cir. 2002). Petitioners submitted no evidence to show that Mr. McRae's payment of restitution to HUD and Mr. Brewer was necessary to preserve the client base of his Schedule C2 business or otherwise to benefit that business.