The last quarter of 2016 saw the introduction of final regulations establishing benchmarks for treating a debt instrument as true debt for U.S. income tax purposes.  These regulations apply to companies over a certain size issuing debt instruments exceeding $50 million.  Debt issued by owner-managed companies are not covered by the regulations and, as a result, tests established by case law will continue to apply.  Galia Antebi and Kenneth Lobo look at a relatively recent case, Sensenig v. Commr., in which the standard tests were applied – the equivalent of comfort food for tax lawyers.