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underlying the stock subscription plan, and the apparent waltz
of (1) first-year subscription interest under the leasing
corporation plan, (2) distribution checks under the leasing
corporation plan, and (3) leverage loan funds in each of the
stock subscription, stock purchase, and leasing corporation
plans.
In sum, considering Judge Goffe's copious list of factors
in support of his conclusion that Mr. Kersting and program
participants had an understanding regarding the stock surrender
policy, as well as Judge Goffe's alternative analyses in support
of his holding that primary loans did not constitute genuine debt
and that interest on primary loans was not paid within the
meaning of section 163, we are convinced that Mr. Thompson's
testimony was not material to the outcome in Dixon II.
Judge Goffe also determined that leverage loans did not
represent genuine debt because of several factors, including the
waltzing of funds, backdating of documents, substance not
following form, and mutual expectations of no personal liability.
Again, given the variety of the factors cited by Judge Goffe, we
are convinced that Mr. Thompson's testimony was not material to
Judge Goffe's holding that leverage loans did not represent
genuine debt.
iii. Additions to Tax
Judge Goffe sustained respondent's determinations that the
Thompsons were liable for interest computed at the increased rate
prescribed in section 6621(c) for 1981, and that the Youngs and
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