Haworth H. Parks v. Commissioner of Internal Revenue

ORDER

This appeal involves the single issue of whether the appellee taxpayers realized taxable income as a result of interest-free loans they received from a close corporation of which they were officers, directors, and shareholders.

The facts are stipulated. During the years 1972 to 1974, the corporation made loans to the taxpayers. No interest was charged and none was paid. There is no dispute that the loans were bona fide; the Commissioner did not seek to tax the proceeds of the loan but rather sought to include in gross income the benefit received from having the use of the money without…