What code section or regulation covers Carolina in borrowing money from the estate? I can't figure out if it increase her debt basis or not.

iSecurity S Corporation Research Issue One of your wealthy clients, Carolina, invests $100,000 for sole ownership of an electing S corporation's stock. The corporation, iSecurity, is in the process of developing a new electronic security product. Carolina anticipates that the new business will need approximately $200,000 in capital (other than trade payables) during the first two years of its operations before it starts to earn sufficient profits to pay a return on the shareholder's investment. The first $100,000 of its total is to come form the contributed capital. The remaining $100,000 of funds will come from one of the following three sources: Have the corporation borrow the $100,000 from a local bank. Carolina is required to serve as guarantor for the loan. Have the corporation borrow $100,000 from the estate of Carolina's late husband, Fernando. Carolina is the sole beneficiary of the estate. Have Carolina lend $100,000 to the corporation from her personal funds. iSecurity will pay interest at a rate acceptable to the IRS. During the first two years of operations, iSecurity anticipates losing $125,000 before it begins to earn a profit. Your tax manager has asked you to evaluate the tax ramifications of each of the three financing alternatives. Prepare a memorandum to the tax manager outlining the information you found in your research