I was wondering if any tax professionals have ever seen using a stress test model with different variables to determine if a note is debt or equity to a corporation. The corporation only assets are loan receivables from individual timeshare owners. To finance the purchase of these receivables, the corporation issues notes. I want to know if any of your tax professionals have used a stress test model (changing the default rate of the timeshare receivables) to determine if the issued notes are debt or equity for federal tax purposes? The corporation has the minimum capital requirements. Could the issued notes be considered equity, than debt, if the timeshare notes default rate is too great or the timing of the defaults create a cash flow issue?