-40-
This factor is either inapplicable or does not support a
finding that the transfers created bona fide debt.
7. Presence or Absence of Security
The absence of security for the repayment of transferred
funds weighs strongly against a finding of bona fide debt. See
Bayer Corp. v. Mascotech, Inc. (In re Autostyle Plastics, Inc.),
supra at 752; Roth Steel Tube Co. v. Commissioner, supra at 632;
Lane v. United States, supra at 1317; Raymond v. United States,
supra at 191; Austin Village, Inc. v. United States, 432 F.2d
741, 745 (6th Cir. 1970).
The disputed transfers were unsecured.
This factor weighs toward a finding that the transfers did
not create bona fide debt.
8. Inability To Obtain Comparable Financing
The question of whether a transferee could have obtained
comparable financing from an independent source is relevant in
measuring the economic reality of a transfer. See Roth Steel
Tube Co. v. Commissioner, supra at 631; Estate of Mixon v. United
States, supra at 410; Nassau Lens Co. v. Commissioner, 308 F.2d
39, 47 (2d Cir. 1962), remanding 35 T.C. 268 (1960). Evidence
that a transferee could not at the time of the transfer obtain a
comparable loan from an arm’s-length creditor weighs against a
finding of bona fide debt. See Roth Steel Tube Co. v.
Commissioner, supra at 631; Stinnett’s Pontiac Serv., Inc. v.
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