Burgess J.W. Raby & William L. Raby have published Loans to and From Shareholders: My Pocket or Yours?, also available on the Tax Analysts web site as Doc 2005-6543, 2005 TNT 61-86. Here is the Introduction:
Some loans are not loans for federal income tax purposes. Amounts loaned by a corporation to a shareholder may for income tax purposes be distributions, and amounts loaned to a corporation may be treated as equity. That situation continues to confuse taxpayers, as it has in some recent cases.



