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believe that the small gap in the record as it pertains to this
factor counts against petitioner. Petitioner frequently and
regularly advanced funds throughout the subject years to or on
behalf of Kenilworth, and petitioner has supplied the Court with
reams of documents relating to these advances. We could sift
through these documents and arrive at fair estimations of the
debt to equity ratio on many of the relevant dates. We refuse to
do so, however, because we do not believe that these estimations
would be meaningful enough to cause this factor to lean in one
direction or the other.
This factor is neutral, and we give it no weight.
ix. Identity of interest
Advances made by stockholders in proportion to their
respective stock ownership point towards equity. A sharply
disproportionate ratio between a stockholder’s ownership
percentage and the corporation's debt to that stockholder
generally points toward debt. Roth Steel Tube Co. v.
Commissioner, supra at 630; Estate of Mixon v. United States,
supra at 409; American Offshore, Inc. v. Commissioner, supra at
604.
Petitioner did not have a direct stock interest in
Kenilworth. Thus, the advances from petitioner to Kenilworth
bore no relationship to a stockholding that petitioner had in
Kenilworth. Respondent argues that the advances were actually
contributions to Kenilworth's capital that were considered made
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