 | United States. Congress. Senate. Committee on Finance - 1969 - 406 pages
...other factors added by regulations. The factors specifically listed are as follows: (1) Whether there is a written unconditional promise to pay on demand or on a specified date a sum certain in money in return for an adequate consideration in money or money's worth, and to pay... | |
 | United States. Internal Revenue Service - 1970 - 744 pages
...exists. The factors so set forth in the regulations may include among other factors: " (1) whether there is a written unconditional promise to pay on demand or on a specified date a sum certain in money in return for an adequate consideration in money or money's worth, and to pay... | |
 | Practising Law Institute, United States. Economic Development Administration - 1971 - 302 pages
...factors would indicate that a particular advance should be considered debt rather than equity: (a) There is a written unconditional promise to pay on demand or on a specified date a sum certain, and to pay a fixed rate of interest thereon; (b) the right to repayment of principal... | |
 | United States. Tax Court - 1988 - 1400 pages
...exists. The factors so set forth in the regulations may include among other factors: (1) whether there is a written unconditional promise to pay on demand or on a specified date a sum certain in money in return for an adequate consideration in money or money's worth, and to pay... | |
 | United States. Congress. Senate. Committee on Finance - 1982 - 378 pages
...would not be terminated if the corporation has a "safe harbor" outstanding straight-debt instrument --a written unconditional promise to pay on demand or on a specified date a sum certain in money, with a fixed interest rate, which is not convertible into stock -- which is... | |
 | United States. Congress. Joint Committee on Taxation - 1982 - 36 pages
...is held by a person who is eligible to hold subchapter S stock. Straight-debt would generally mean a written unconditional promise to pay on demand or on a specified date a sum certain in money, so long as the interest rate is fixed and the instrument is not convertible... | |
 | Allan J. Samansky, James Charles Smith - 1985 - 840 pages
...specifies that "straight debt" will not be considered a second class.32 Straight debt is defined as: "any written unconditional promise to pay on demand or on a specified date a sum certain in money if — 23I.RC § 1361(bX2XC) (corporations electing to take tax credit for income... | |
 | United States. Tax Court - 1988 - 1406 pages
...exists. The factors so set forth in the regulations may include among other factors: (1) whether there is a written unconditional promise to pay on demand or on a specified date a sum certain in money in return for an adequate consideration in money or money's worth, and to pay... | |
 | Claus Luttermann - 1998 - 640 pages
...exists. The factors so set forth in the regulations may include among other factors: (l) whether there is a written unconditional promise to pay on demand or on a specified date a sum certain in money in return for an adequate consideration in money or money 's worth, and to pay... | |
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The factors so set forth in the regulations may include among other factors: (1) Whether there is a written unconditional promise to pay on demand or on a specified date a sum certain in money in return for an adequate consideration in money or money's... 
