Estate of Arbury v. Commissioner
United States Tax Court
P made a series of interest-free demand loans to two of her children. Following the Supreme Court's decision in Dickman v. Commissioner, 465 U.S. 330 (1984), P filed amended gift tax returns in which she valued the gift element of the interest-free loans by using the maximum rate of interest which she could have legally charged her children under a Michigan usury statute.
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P made a series of interest-free demand loans to two of her children. Following the Supreme Court's decision in Dickman v. Commissioner, 465 U.S. 330 (1984), P filed amended gift tax returns in which she valued the gift element of the interest-free loans by using the maximum rate of interest which she could have legally charged her children under a Michigan usury statute. Held, the proper valuation of the gift element of an interest-free demand loan does not depend on how much interest the lender could have legally charged to a particular borrower; rather, the value of the gift element is…
1Opinion of the Court
Estate of Anderson Arbury, Deceased, Dorothy D. Arbury, Independent Personal Representative, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Arbury v. Commissioner
Docket Nos. 8683-87, 8684-87, 39312-87, 39313-87
United States Tax Court
93 T.C. 136; 1989 U.S. Tax Ct. LEXIS 108; 93 T.C. No. 14;
July 31, 1989July 31, 1989, Filed
Decision will be entered under Rule 155.
P made a series of interest-free demand loans to two of her children. Following the Supreme Court's decision in Dickman v. Commissioner, 465 U.S. 330 (1984), P filed amended gift tax returns in which she…
2Cases cited14 opinions
- Anniston Manufacturing Co. v. DavisSupreme Court of the United States · 1937
- Dickman v. CommissionerSupreme Court of the United States · 1984
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
- Minahan v. CommissionerUnited States Tax Court · 1987
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