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suffered by the Government’s 15-year failure to issue final
regulations, although Congress, in the 1984 statute, mandated
that certain legislative regulations be promulgated. Petitioner
also contends that case precedent, before the 1984 enactment of
section 7872, established that imputed interest should apply to a
loan by a corporation only if the loan is to a sole or
controlling shareholder. In addition, petitioner contends that
section 7872 legislative history supports its contention that the
section is limited to situations involving controlling
shareholders.
The below-market loan provisions of section 7872 apply,
among other circumstances, to “Any below-market loan directly or
indirectly between a corporation and any shareholder of such
corporation.” Sec. 7872(c)(1)(C). In that respect, petitioner
reads section 7872 as referring to a loan by a corporation to its
majority or controlling shareholder or to a loan by a corporation
to an entity in which one of the lending corporation’s
shareholders owns a majority interest. Petitioner relies on the
fact, in this case, that there is no one individual with a
majority of its shares or who is a controlling shareholder of
petitioner. Petitioner also relies on the fact that no
individual shareholder of petitioner had a majority or
controlling interest in any of the entities to which “indirect”
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