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application to loans made by banks in the ordinary course of
business, regardless of whether the loans are characterized as
generating interest or original issue discount.4 We, therefore,
hold that section 1281(a)(1) does not apply to the loans in
issue.
Decision will be entered
for petitioner.
4Because of our legal conclusion, there is no need to decide
whether respondent is correct in characterizing the loans in
issue as generating original issue discount.
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Last modified: May 25, 2011