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sister corporations, and while their ability to repay principal
or to pay interest was decreasing, petitioner continued to
advance ever-increasing amounts.
Petitioner’s actions and the facts in this record do not
portray the type of debtor-creditor relationship that petitioner
must show to qualify for ordinary loss treatment under section
166, I.R.C. 1986. Considering the lack of intent evidenced by
the manner in which repayment was made and interest accrued and
the lack of objective evidence of debt, after reconsidering the
evidence, we reach the same conclusion as we reached in Cerand I-
- petitioner was an investor in the three sister corporations and
is not entitled to debt treatment under section 166.
To reflect the foregoing,
Decision will be entered
for respondent.
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