Chez Guevara Inc. has the following balance sheet: Assets Adj. Basis FMV Liabilities and Capital Cash Liabilities: Building Goodwill $ 1,920,000 $1,920,000 20,000 80,000 40,000 $ 900,000 900,000 Friendly Bank Shareholder loans Capital: Common stock 240,000 $ 2,040,000 $ 1,940,000 $2,040,000 The terms of the loan from Friendly Bank state that interest will be paid semi-annually at an interest rate that is two points above the prime rate, and the principal is due in ten years. The loan is secured by a mortgage on the building. Each of the three shareholders owns 100 shares of stock. Each of the shareholders has also loaned the corporation $300,000. The loans take the form of a five-year unsecured note with variable interest payable annually at 1 point below the prime rate. How likely is it that the Internal Revenue Service will seek to reclassify the shareholder loans as equity? What factors would be relevant to making this determination? Chez Guevara Inc. has the following balance sheet: Assets Adj. Basis FMV Liabilities and Capital Cash Liabilities: Building Goodwill $ 1,920,000 $1,920,000 20,000 80,000 40,000 $ 900,000 900,000 Friendly Bank Shareholder loans Capital: Common stock 240,000 $ 2,040,000 $ 1,940,000 $2,040,000 The terms of the loan from Friendly Bank state that interest will be paid semi-annually at an interest rate that is two points above the prime rate, and the principal is due in ten years. The loan is secured by a mortgage on the building. Each of the three shareholders owns 100 shares of stock. Each of the shareholders has also loaned the corporation $300,000. The loans take the form of a five-year unsecured note with variable interest payable annually at 1 point below the prime rate. How likely is it that the Internal Revenue Service will seek to reclassify the shareholder loans as equity? What factors would be relevant to making this determination