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to organize his affairs as he chooses, nevertheless, once having
done so, he must accept the tax consequences of his choice,
whether contemplated or not, * * * and may not enjoy the benefit
of some other route he might have chosen to follow but did not”).
The record does not support petitioner’s contention that the
GXE loan was, in substance, a loan solely from GITIC and not from
GXE. Mr. Wong testified that it was GITIC that negotiated the
GXE loan with petitioner and that petitioner recorded the GXE
loan as a loan from GITIC in its accounting records. However,
petitioner’s general ledger segregates and identifies interest
payments made to GXE, and petitioner does not dispute that it
paid interest directly to GXE on the GXE loan. In addition,
petitioner’s original 1994 Form 5472 and amended Forms 5472 for
each of the years in issue reported that petitioner paid interest
to GXE. Moreover, in the September 8, 1998, letter, petitioner
admits that it had at least one GXE loan that was separate from
the loan it had with GITIC. The GXE loan agreement lists GXE as
the lender. Although the officer who signed the loan agreement
on behalf of GXE was also an officer of GITIC, related companies
frequently share officers and employees. See United States v.
Bestfoods, 524 U.S. 51, 69 (1998) (acknowledging that it is not
unusual for a parent corporation and its subsidiary to share
directors and officers who can and do represent the two
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