Delta Plastics, Inc. - Page 13




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          payment of principal and designated interest set forth by the               
          debenture notes were honored by petitioner.                                 
               The debenture holders’ expectation of repayment at the time            
          the debenture notes were executed was reasonable because the                
          debenture holders had an understanding and knowledge of                     
          petitioner’s business and a reasonable expectation of its likely            
          success.  For 1993 through the time of trial in 2002, petitioner            
          timely made the principal and designated interest payments due on           
          the debenture notes, and a majority of the objective factors                
          indicate that a debtor-creditor relationship existed between                
          petitioner and the debenture holders with regard to the debenture           
          funds.                                                                      
               We conclude that petitioner properly treated the $1,337,500            
          in debenture funds as debt.  For 1996, petitioner is entitled to            
          an interest deduction for the $93,746 it paid as interest on the            
          debenture notes.                                                            
               To reflect the foregoing,                                              

                                             Decision will be entered                 
                                        for petitioner.                               














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