Todd II, et ux. v. Comr., T.C. Memo. 2011-123

(loan taken out against wife's life insurance policy funded by neurosurgeon husband's wholly-owned corporation for "unexpected housing costs" not bona fide; no contemporaneous memorialization of indebtedness at time of distribution, terms of promissory note not heeded, market rate of interest not charged, quarterly payments not made as not required, no attempt to collect amounts due upon default; loan was taxable distribution).