According to 26 USCS § 1275 [Title 26. Internal Revenue Code; Subtitle A. Income Taxes; Chapter 1. Normal Taxes and Surtaxes; Subchapter P. Capital Gains and Losses; Part V. Special Rules for Bonds and Other Debt Instruments; Subpart A. Original Issue Discount], the term ‘personal use property’ means “any property substantially all of the use of which by the taxpayer is not in connection with a trade or business of the taxpayer or an activity described in 26 USCS § 212. The determination of whether property is described in the preceding sentence shall be made as of the time of issuance of the debt instrument.