- 12 - The resolution of whether the substance of the transaction at issue is a loan may obviate the necessity of deciding whether the all events test is satisfied or whether petitioner's ability to pay interest affects the availability of the deductions. For these reasons, we conclude that petitioners' motion for partial summary judgment must be denied. An appropriate order will be issued.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011