Cerand & Company, Inc. - Page 15




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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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