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The technical correction is not applicable to petitioner's
transactions. This amendment to the statute was intended to give
the Department of the Treasury authority to expand the category
of demand loans to include loans that have indefinite maturities
and are not payable on the demand of the lender. We note that
all demand loans by their very nature have indefinite maturities.
See Dickman v. Commissioner, 465 U.S. 330, 337 (1984) (analyzing
the "uncertain tenure of a demand loan"). If all loans with
indefinite maturities were classified as term loans under the
statute, no loan would meet the definition of a demand loan.
"[W]e have employed the rule that statutes are to be construed so
as to give effect to their plain and ordinary meaning unless to
do so would produce absurd or futile results * * *. Furthermore,
all parts of a statute must be read together, and each part
should be given its full effect." Phillips Petroleum Co. v.
Commissioner, 101 T.C. 78, 97 (1993), affd. without published
opinion 70 F.3d 1282 (10th Cir. 1995). Petitioner's loans,
payable on demand and having indefinite maturities, are demand,
rather than term, loans. Next, we must determine whether
petitioner's loans are subject to a below-market interest rate.
B. Below-Market Interest Rate
A demand loan is a below-market loan if it is interest free
or if interest is provided at a rate that is lower than the
applicable Federal rate (AFR) as determined under section
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