June Cordes, et al. - Page 27




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          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 interest                






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