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T.C. 255, 266 (1969), affd. 422 F.2d 198 (5th Cir. 1970). Courts
have focused on certain objective factors to distinguish bona
fide loans from disguised dividends, compensation, and
contributions to capital. The factors considered relevant for
purposes of identifying bona fide loans include (1) the existence
or nonexistence of a debt instrument; (2) provisions for
security, interest payments, and a fixed payment date; (3)
treatment of the funds on the corporation’s books; (4) whether
repayments were made; (5) the extent of the shareholder’s
participation in management; and (6) the effect of the “loan” on
the transferee’s salary. Haber v. Commissioner, supra at 266.
When the individual is in substantial control of the corporation,
as petitioner is in this case, special scrutiny of the situation
is necessary. Id.; Roschuni v. Commissioner, 29 T.C. 1193, 1202
(1958), affd. 271 F.2d 267 (5th Cir. 1959).
From the record, it is possible that WFIC lent money to
Taxman in 1991, which then lent the amounts to petitioner for his
furniture purchase. However, although petitioner has shown that
WFIC may have lent amounts to Taxman during 1991, he has not
shown any evidence of a loan from Taxman to himself during 1991.
He does not claim that a debt instrument was created, and none is
in the record. Petitioner has provided no evidence that he
offered anything as security for the loan, interest payments on
the principal amount, or fixed payment dates. As we stated
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