J.J. Zand - Page 158

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          loans made by trusts established for the benefit of petitioner's            
          three daughters.  In 1977 petitioner established these six                  
          trusts, two for each of his three daughters.  The two trusts for            
          each daughter were in the amounts of $25,000 and $75,000.  Each             
          of the trusts was for a term of 10 years and 1 day.  The three              
          trustees were Priscilla Meier, petitioner's longtime employee,              
          and George Hairston and David Johnston, attorneys in the law firm           
          of George, Greek.  The terms of the trust agreements placed                 
          investment discretion solely in the hands of the three trustees             
          acting in unison and not separately.                                        
               In 1977 the trust funds were lent to CDC, a corporation in             
          which petitioner held a controlling interest.  The loans were               
          repaid to the trusts.  On February 5, 1980, the corpus of each              
          trust was lent to petitioner personally with a rate of return of            
          12 percent per annum.  As security for the loans, petitioner gave           
          mortgages on his residence and condominium.  He claimed interest            
          paid to the trusts in the amounts of $30,000 and $45,000 for the            
          years 1980 and 1981, respectively.  At the end of the years 1980            
          and 1981, the loans had not been repaid.  The funds in the trusts           
          were paid to petitioner personally or were invested in entities             
          that he controlled.                                                         
               Respondent contends that the claimed interest deductions of            
          $30,000 for 1980 and $45,000 for 1981 should be disallowed                  
          because petitioner should be treated as the "owner" of the                  





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