The current invention is a system, method and program of making loans with tax benefits. Instead of a conventional loan note, or mortgage the financer takes a portion of equity in the company (this may, or may not hold real estate). This has the advantage of not being a formal 2nd mortgage, as this is often forbidden by a primary financer (though it can be secured by a lien on an asset) in addition to the ownership of stock. This is often called an “assignment of partnership interest”. The gradual payments to the financer of interest and principal perform much like a loan note, however payments have the advantage of technically being dividends rather than interest, so are taxed at a lower rate.