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Paraphrase this The Tax Court determined that the loans should be treated as equity for tax purposes by applying the 13 factors outlined in Estate

Paraphrase this "The Tax Court determined that the loans should be treated as equity for tax purposes by applying the 13 factors outlined in Estate of Mixon, 464 F.2d 394 (5th Cir. 1972). These factors are: (1) the names given to the certificates evidencing the indebtedness; (2) presence or absence of a fixed maturity date; (3) source of payments; (4) right to enforce payment of principal and interest; (5) participation in management flowing as a result; (6) status of the contribution in relation to regular corporate creditors; (7) intent of the parties; (8) "thin" or adequate capitalization; (9) identity of interest between creditor and stockholder; (10) source of interest payments; (11) ability of the corporation to obtain loans from outside lending institutions; (12) extent to which the advance was used to acquire capital assets; and (13) failure of the debtor to repay on the due date or seek a postponement

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