Cerand & Company, Inc. - Page 14




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          merely book entries.  As soon as some amount was repaid to                  
          petitioner (always substantially less than had been advanced)               
          petitioner would make another, usually larger advance to the                
          sister corporations.  Significantly, we note that while the                 
          repayments were decreasing and the sister corporations’ ability             
          to repay was dwindling, petitioner continued to advance funds in            
          progressively larger amounts.                                               
               It is important to note that no interest was actually paid             
          to petitioner by the sister corporations.  In a similar manner to           
          the repayments, the interest accruals appear to be an attempt to            
          simulate the existence of debt.  We note that the accruals were             
          limited, sporadic, and had no apparent fixed percentage.                    
               As noted by the Court of Appeals for the D. C. Circuit,                
          petitioner reported taxable income only in 2 of the years under             
          consideration, 1986 and 1987.  In five of the periods in which              
          interest was accrued by petitioner, the accrual of interest                 
          merely reduced petitioner’s losses and did not result in taxable            
          income.  Put another way, of the $175,662 of interest accrued and           
          reported by petitioner, only $45,253 (about one-fourth) resulted            
          in additional tax burden on petitioner.                                     
               When compared to the outstanding cumulative balance, the               
          amount of interest accrued was substantially less in percentage             
          than the going rate of interest during the period under                     
          consideration.  Again, no interest was actually paid by the                 






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