PK Ventures, Inc. and Subsidiaries, et al. - Page 18

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               Petitioners contend that, because the Summit Trust loan was            
          a bona fide loan, the transfers from PK Ventures to the Zephyr              
          purchasers were also bona fide loans.  Petitioners are                      
          essentially relying on the circumstances surrounding the Summit             
          Trust loan to establish that the transfers from PK Ventures to              
          the Zephyr purchasers were bona fide loans.  Petitioners do not             
          cite any authority to support this contention.  After considering           
          the relevant factors and weighing the evidence, we reject                   
          petitioners’ contention that the transfers from PK Ventures to              
          the Zephyr purchasers were bona fide loans for the reasons                  
          discussed below.                                                            
               First, PK Ventures did not receive promissory notes from the           
          Zephyr purchasers in exchange for its transfer of $1 million to             
          them.                                                                       
               Second, no evidence indicates that the Zephyr purchasers               
          made any agreement with PK Ventures as to the time of repayment             
          or the interest to be paid.                                                 
               Third, while PK Ventures provided security for its repayment           
          of the Summit Trust loan to Summit Trust, no evidence indicates             
          that the Zephyr purchasers provided any collateral or security              
          for repayment of the transfers that they received from                      
          PK Ventures.                                                                
               Fourth, the Zephyr purchasers did not make any payments of             
          principal or interest to PK Ventures, and no accrued interest               






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