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Under the imputed interest rules, the taxpayer who makes a below-market loan may be required to recognize income he or she did not actually receive.

Under the imputed interest rules, the taxpayer who makes a below-market loan may be required to recognize income he or she did not actually receive. For example, assume that Christian loans $200,000 to Mia, his daughter, to start a business (income-producing property). Christian does not charge interest because Mia needs the funds to operate a struggling startup business. Why should Christian be required to pay tax on a made-up number (i.e., the interest he did not charge)? This type of income is sometimes referred to as phantom income.

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