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with the economic reality of creating a debtor-creditor
relationship. Dixie Dairies Corp. v. Commissioner, supra at 494.
The objective indicia of a bona fide debt include whether a
note or other evidence of indebtedness existed and whether
interest was charged. See Clark v. Commissioner, 18 T.C. 780,
783 (1952), affd. 205 F.2d 353 (2d Cir. 1953). Also considered
are the existence of security or collateral, the demand for
repayment, records that may reflect the transaction as a loan,
and the borrower's solvency at the time of the loan. See Road
Materials, Inc. v. Commissioner, 407 F.2d 1121 (4th Cir. 1969),
affg. in part and vacating in part and remanding T.C. Memo. 1967-
187; Zimmerman v. United States, 318 F.2d 611, 613 (9th Cir.
1963).
Petitioner and Maxted did not document their relationship
through the issuance of a promissory note. In addition,
petitioner did not ask for collateral or security in exchange for
the $10,000. However, the absence of formal indicia of debt is
not dispositive here. Rather, the facts in the present case
indicate petitioner's intent to create a debt. Specifically,
petitioner believed Maxted's word that he would repay the advance
because of a previous business relationship with him and their
Montana roots. Further, petitioner visited Maxted's car-shade
operation, observed the construction and packaging of the car
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