Rountree Cotton Co. - Page 12




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          petitioner’s complaint about the absence of final regulations,              
          respondent argues that the statute is clear and unambiguous                 
          concerning the issues before the Court and that there is no need            
          to seek interpretation or guidance from any regulation.  In                 
          addition, respondent contends that the section 7872(h) areas for            
          which regulations were mandated and which were referenced by                
          petitioner have no bearing on the questions before the Court.               
               We first consider the statutory language in our search for             
          an answer.  See United States v. American Trucking Associations,            
          Inc., 310 U.S. 534, 542-543 (1940); Hospital Corp. of Am. v.                
          Commissioner, 107 T.C. 116, 128 (1996).  If the language of the             
          statute is clear, we need look no further in deciding its                   
          meaning.  See Sullivan v. Stroop, 496 U.S. 478, 482 (1990).                 
               Petitioner’s Controlling Shareholder Argument--Below-market            
          loans between corporations and shareholders may come within the             
          provision of section 7872.  In particular, section 7872(c)(1)(C)            
          makes section 7872 applicable to “Any below-market loan directly            
          or indirectly between a corporation and any shareholder of such             
          corporation.”  The loans in question were without interest, and,            
          if the other threshold requirements are met, the loans would be             
          subject to section 7872.                                                    
               Petitioner’s primary attack on respondent’s determination is           
          based on the fact that each of its shareholders has less than a             
          majority or controlling interest in petitioner and that the                 






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