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fide indebtedness theory, described above. Thus, we must
consider the application of section 183 no matter how we
decide the other issues. This is the third issue for
decision in these cases.
It appears that each partnership also deducted, as
interest, amounts paid or accrued during the years in issue
with respect to certain funds advanced to it by EPIC, as
general partner. By implication, the notices of FPAA take
the position that any such unsecured advance made by EPIC
to either partnership did not create a bona fide
indebtedness of the partnership to EPIC and any amount
paid or accrued with respect to any such advance is not
deductible under section 163(a). This is the fourth issue
for decision in these cases.
It also appears that EA 84-III deducted, as interest,
amounts paid or accrued during 1985 with respect to 16
promissory notes issued to CSL. Each of those promissory
notes was secured by a deed of trust on one of the
properties that had been purchased by EA 84-III in 1983.
As mentioned above, the notices of FPAA disallow all of the
interest deductions claimed by the partnerships on the
ground that the amounts deducted were not shown to have
been paid as interest on a bona fide debt. Thus, the fifth
issue for decision in these cases is whether any of the 16
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