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contribution of $500 and the subsequent advances were apparently
its only other source of funds. Id. at 894-895. Here, National
had a capital base of $900, with a debt to equity ratio of
roughly 166 to 1. As in Thompson, insufficient capital existed
to fund National's operations at the time of petitioner's
advance. See also Tyler v. Tomlinson, supra at 848-849.
8. Identity of Interest Between Creditor and Stockholder
If stockholders make advances in proportion to their
respective stock ownership, a capital contribution is indicated.
Estate of Mixon v. United States, 464 F.2d at 409. Petitioner
owned 33 percent of National's stock and contributed $74,700 to
the corporation. Brands, who owned 11 percent of the stock,
contributed precisely one-third of that amount, or $24,900. A
22-percent shareholder (the record is unclear whether Tucker or
Tavistock) contributed exactly two-thirds of the amount of
petitioner's advance, or $49,800. Although Burkhalter did not
make an advance, at the time the stock was originally distributed
the parties had apparently agreed to exempt him from making
further monetary contributions.
9. Ability To Obtain Loans From Outside Lending
Institutions
If an ordinary reasonable creditor would not lend funds to a
corporation when funds are advanced by a shareholder, the advance
is more likely to be equity. Estate of Mixon v. United States,
464 F.2d at 410; American Offshore, Inc. v. Commissioner, supra
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