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If the IRS Reclassifies Debt as Equity Under § 385,the

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If the IRS reclassifies debt as equity under § 385,the repayment of the debt by the corporation to the shareholder is treated as a dividend,assuming adequate E & P.


Definitions:

Morality

Principles concerning the distinction between right and wrong or good and bad behavior; the goodness or badness of human character.

Perceptual Constancy

The psychological feature that allows the perception of an object to remain relatively unchanged despite variations in the viewing conditions like distance or lighting.

Accommodation

In cognitive psychology, the process by which an individual revises existing cognitive schemas, perceptions, and understanding so that new information can be incorporated.

Linear Perspective

A technique in art and photography that creates the illusion of depth and distance on a flat surface, using converging parallel lines.

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