- 4 - outstanding for 7 years. Accordingly, among the three sister corporations, advances were outstanding to petitioner for a total of 22 annual accounting periods. Petitioner accrued and reported interest income with respect to 8 of the 22 accounting periods. No interest was accrued or reported with respect to 14 of the 22 annual accounting periods. The total amount of interest accrued and reported by petitioner for the period 1984 through 1991 was $175,662. No amount of the accrued and reported interest was paid by the sister corporations. Instead, it was rolled over into a note receivable each year. The reported interest was sporadic in amount and also varied as a percentage of the outstanding amount of advances. Treating the cumulative advances1 outstanding annually for each sister corporation as the denominator and the amount of reported interest as the numerator,2 the following percentage rate of interest would result: 1 The outstanding annual cumulative advances used take into account increases for advances and reductions for any payments or credits during the year. 2 No interest income was accrued or reported by petitioner with respect to one of the three sister corporations--Cerand AviationPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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