Sue is a solicitor who borrows $100,000 and lends it, interest-free, to ABC Pty Ltd. ABC

lends the money, interest-free, to DEF Pty Ltd. DEF invests the money in a business. Profits are distributed to shareholders, one of whom is Sue.

Is Sue entitled to a deduction for interest on the loan?

You should support your answer by referring to the following Taxation Law Cases: Sheil v FCT (1987), FCT v Total Holdings (Australia) Pty Ltd (1979)