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transfer, and he effectively owned 100 percent of petitioner’s
equity at the time of the transfer.
This factor weighs toward equity.
vii. Presence or Absence of Security
The absence of security for purported debt weighs toward
equity. Roth Steel Tube Co. v. Commissioner, supra at 632;
Lane v. United States, supra at 1317; Raymond v. United States,
511 F.2d at 191; Austin Village, Inc. v. United States, 432 F.2d
at 745.
Mr. Mohney did not receive security for his transfer of the
subject properties to petitioner.
This factor weighs toward equity.
viii. Inability to Obtain Financing
The question of whether a transferee could have obtained
comparable financing is relevant in measuring the economic
reality of a transfer. Estate of Mixon v. United States, 464
F.2d at 410; Nassau Lens Co. v. Commissioner, 308 F.2d 39, 47
(2d Cir. 1962), remanding 35 T.C. 268 (1960). Evidence that the
taxpayer could not obtain loans from independent sources weighs
toward equity. Calumet Indus., Inc. v. Commissioner, 95 T.C.
257, 287 (1990). We look to whether the terms of the purported
debt were a "patent distortion of what would normally have been
available" to the debtor in an arm’s-length transaction. See
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