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the below market rate loan under irc 7872 do not apply to a gift loan between...

the below market rate loan under irc 7872 do not apply to a gift loan between individuals of    unless it is to the acquisition of income producing assests

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Section 7872 does not apply to any gift loan directly between individuals on any day on which the aggregate amount of loans between such individuals is not more than $10,000.52 This exception does not apply to the extent that any such loans are used to purchase or carry income producing assets.53 Under another special rule pertaining to gift loans, there is no retransfer of forgone interest from lender to borrower unless the borrower has net investment interest.54 This exception does not apply to any loan on any day on which the aggregate amount of loans between borrower and lender exceeds $100,000.55 This special rule does not apply where one of the principal purposes of a loan is the avoidance of any federal tax

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