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purported loans. There is no evidence that EIC ever attempted to
enforce repayment. Additionally, there is no evidence that EIC
either requested or received any security or collateral for the
loans. See Zimmerman v. United States, 318 F.2d 611, 613 (9th
Cir. 1963).
Petitioner argues that, in later years, he and Mrs. Wang
repaid some of the loans. Petitioner directs our attention to
EIC's Federal income tax returns for subsequent years, wherein
the reported balance in the "Loans to shareholder" account
decreased. We are not persuaded that this evidence is sufficient
to carry the day for petitioner. No evidence was introduced
concerning the form of the purported loan repayments made by
petitioner. Cases have discounted the significance of repayments
that consisted merely of entries in the corporation's books, as
opposed to cash transfers made by the shareholder. Compare
Boecking v. Commissioner, T.C. Memo. 1993-497 (shareholder's
bonuses that were credited to the shareholder's loan account were
simply bookkeeping entries and did not establish the existence of
bona fide loans), with M. J. Byorick, Inc. v. Commissioner, T.C.
Memo. 1988-252 (repayment is strong evidence that a bona fide
loan exists).
Petitioner also argues that a debtor/creditor relationship
existed throughout the years at issue. He asserts that
documentary evidence consisting of financial statements, minutes
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