There was a close debtor/creditor relationship

There was a close debtor/creditor relationship o AFI continuously advanced additional operating funds to AFI o There were no fixed maturity dates on advances o There were no evidences of indebtednesses, no debt instruments o No interest was paid o The intent of the parties was vague o BOI was thinly capitalized gent Fairly accordingly increased AFI’s taxable income by the $2,101,000. A Preliminary Notice to that effect was issued to AFI. A1, Ben, and Charlie stongly disagree with the Agent’s determination, believing firmly that the debt was bad and that no additional tax is due by AFI. AFI has engaged you for advice as to whether and how to proceed with this issue. Is the charge-offlegitimate? Is it in fact equity? How should they proceed? Required – (1) Client File Memo ‘ Q) Court Case Brief of key precedent(s) (not more

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