- 27 - unrelated parties under similar circumstances, considering all the relevant factors. Sec. 1.482-2(a)(2)(i), Income Tax Regs. Petitioners have not introduced evidence of actual rates charged in transactions with or between unrelated taxpayers, nor have they offered any but the barest evidence relevant to deciding what a chargeable interest rate would be in an independent transaction involving unrelated parties under similar circumstances. Petitioners provided us only with the original principal amounts of the loans and have indicated that the loans were unsecured. Petitioners introduced no evidence regarding other relevant factors, including the duration of the loans, CFC’s credit standing, and the prevailing interest rates at CFC’s or the Cordeses’ situs for comparable loans between unrelated parties. Id. Because petitioners have failed to establish that respondent’s determinations are incorrect, let alone that 18 percent is an arm’s-length rate of interest on the three loans under section 1.482-2(a)(2)(i), Income Tax Regs., we must hold for respondent. In holding for respondent, we note that respondent’s concession to reallocate petitioners’ interest income and deductions in accordance with the safe-haven interest rate found in section 1.482-2(a)(2)(iii)(B), Income Tax Regs., satisfies the arm’s-length standard of section 482, and we accept it. The calculation of the appropriate adjustments to CFC’s interestPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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