The other piece is depreciation on any assets bought during the "missing" years. If the corporation is in a position to Section179 everything - or if they didn't buy anything that qualifies as an asset during those years - then if your client can confirm through the SOS's office that the corporation still exists, go for it. Many times, too, you can reinstate a corporation by filing all the back annual reports and paying the fees (plus a sweetener, frequently called a reinstatement fee). Else he has to open a new corporation, get a new EIN, and he can kiss this particular loan goodbye and try again once his paperwork is in order, in two or three years. Of course, no one is going to loan money to a brand-new corporation with zero history... You can't save some people from themselves and it's NOT our job to try.