opinion: The J. F. STEVENHAGEN CO. et al., Appellants, v. The COMMISSIONER OF INTERNAL REVENUE, Appellee. The J. F. STEVENHAGEN CO., Appellee, v. The COMMISSIONER OF INTERNAL REVENUE, Appellant.
  Nos. 76-1265, 76-1266.
  United States Court of Appeals, Sixth Circuit.
  Argued Feb. 7, 1977.
  Decided March 8, 1977.
  Samuel Goldman, Goldman, Greene & Tsarnas, Neil B. Greene, Akron, Ohio, for J. F. Stevenhagen Co., and others.
  Scott P. Crampton, Gilbert Andrews, Asst. Attys. Gen., Tax Div., U. S. Dept, of Justice, Leonard J. Henzke, Richard Farber, Meade Whitaker, Chief Counsel, I. R. S., Washington, D. C., for C, I. R.
  Before PHILLIPS, Chief Judge, EDWARDS, Circuit Judge, and SILER, District Judge.
  Honorable Eugene E. Siler, Jr., United States District Judge for the Eastern and Western District of Kentucky, sitting by designation.
  PER CURIAM.
  These are consolidated appeals from the United States Tax Court, styled as follows: The J. F. Stevenhagen Co., et al. v. Commissioner, No. 2148-72; John F. Stevenhagen and Patricia Stevenhagen v. Commissioner, No. 2149-72, and Jon-Way Developers, Inc. v. Commissioner, No. 2150-72.
  The appellate contention before our court is that certain advances made by two sole and equal shareholders in Jon-Way Developers, Inc., were loans (made directly or through their wholly-owned companies) rather than advances of capital, as determined by the Commissioner. It is also contended that certain payments made by Jon-Way were interest payments on said loans rather than constructive dividends, as determined by the Commissioner.
  On review of the opinion of the Tax Court and the records and briefs in this appeal, this court concludes that the Tax Court properly applied the law of this Circuit to the facts in this case. See Austin Village, Inc. v. United States, 432 F.2d 741, 745 (6th Cir. 1970); Berthold v. Commissioner, 404 F.2d 119, 122 (6th Cir. 1968), and that there were no facts in this record which brought these transactions within the definition of a normal arm’s length loan. The record clearly demonstrates that the Tax Court’s findings of fact are not clearly erroneous.
  The judgment of the Tax Court is affirmed for these reasons and others more fully spelled out in the opinion of the Tax Court, filed June 23, 1975.
  . The J. F. Stevenhagen Co. v. Comm’r, Tax Ct.Mem. 1975-198.
instruction: What follows is an opinion from a United States Court of Appeals.
  Intervenors who participated as parties at the courts of appeals should be counted as either appellants or respondents when it can be determined whose position they supported. For example, if there were two plaintiffs who lost in district court, appealed, and were joined by four intervenors who also asked the court of appeals to reverse the district court, the number of appellants should be coded as six.
  When coding the detailed nature of participants, use your personal knowledge about the participants, if you are completely confident of the accuracy of your knowledge, even if the specific information is not in the opinion. For example, if "IBM" is listed as the appellant it could be classified as "clearly national or international in scope" even if the opinion did not indicate the scope of the business. 
  
  Your task concerns the first listed appellant. The nature of this litigant falls into the category "private business (including criminal enterprises)", specifically "unclear". Your task is to determine what subcategory of business best describes this litigant.
choices: auto industry chemical industry drug industry food industry oil & gas industry clothing & textile industry electronic industry alcohol and tobacco industry other unclear