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we ordinarily consider in our analysis include, but are not
limited to: (1) The name given to the certificate evidencing the
indebtedness, (2) the presence or absence of a fixed maturity
date, (3) the source of payments, (4) the right to enforce
repayment, (5) any increase in management participation as a
result of the advances, (6) the status of the advances in
relation to debts owed to regular corporate creditors, (7) the
intent of the parties, (8) thin or adequate capitalization, (9)
the identity of interest between creditor and stockholder, (10)
payment of interest only out of profits, (11) the ability to
obtain loans from outside lending institutions, (12) the extent
to which the advance was used to acquire capital assets, and (13)
the failure of the corporation to repay on the due date. Am.
Offshore, Inc. v. Commissioner, 97 T.C. 579, 602-606 (1991); see
also Calumet Indus., Inc. v. Commissioner, supra at 285; Anchor
Natl. Life Ins. Co. v. Commissioner, 93 T.C. 382, 400 (1989) (11
factors); Dixie Dairies Corp. v. Commissioner, 74 T.C. 476, 493
(1980) (13 factors). No single factor is determinative, and not
all factors are applicable in each case. Dixie Dairies Corp. v.
Commissioner, supra at 493-494. “The various factors * * * are
only aids in answering the ultimate question whether the
investment, analyzed in terms of its economic reality,
constitutes risk capital entirely subject to the fortunes of the
corporate venture or represents a strict debtor-creditor
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