- 15 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
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