Reginald and Roland (Reginald's son) each own 50% of the stock of Robin Corporation. Reginald's stock interest is entirely redeemed by Robin Corporation. Two years later, Reginald loans Robin Corporation $250,000. The loan to Robin Corporation constitutes a prohibited interest for purposes of the family attribution waiver.

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The Answer of Reginald and Roland (Reginald's son) each own 50% of the stock of Robin Corporation. Reginald's stock interest is entirely redeemed by Robin Corporation. Two years later, Reginald loans Robin Corporation $250,000. The loan to Robin Corporation constitutes a prohibited interest for purposes of the family attribution waiver.

Reginald and Roland (Reginald's Son) Each Own 50% of the Stock