Charlotte Aircraft Corporation and Subsidiaries - Page 12

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                  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.                          
































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Last modified: May 25, 2011