Legal Opinion
Esther C. Dickman, Estate of Paul B. Dickman, Deceased, G. Wendell Smith, Personal Representative v. Commissioner of Internal Revenue
Court of Appeals for the Eleventh Circuit
Decided February 22, 1983No. 81-5297PublishedCited by 13 opinions
1Opinion of the Court
JAMES C. HILL, Circuit Judge:
At issue in this case is whether taxable gifts resulted when lenders made interest-free loans to a relative and to a closely held corporation. The Tax Court ruled that all loans here were on a demand basis and, following its decision in Crown v. Commissioner, 67 T.C. 1060 (1977), aff’d, 585 F.2d 234 (7th Cir. 1978), it held that the loans involved no gift tax consequences. We reverse, holding that such interest-free loans are subject to the gift tax whether the loans are made for a fixed term or are on a demand basis; we remand for further proceedings relevant to…
2Cases cited18 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Dixon v. United StatesSupreme Court of the United States · 1965
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Robinette v. HelveringSupreme Court of the United States · 1943
13 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Dickman v. CommissionerSupreme Court of the United States · 1984
- Johnson & Johnson-Merck Consumer Pharmaceuticals Company v. Rhone-Poulenc Rorer Pharmaceuticals, IncCourt of Appeals for the Third Circuit · 1994
- Ochs v. Lipson (In Re First Central Financial Corp.)United States Bankruptcy Court, E.D. New York · 1999
- J. C. Shepherd v. Comr. of IRSCourt of Appeals for the Eleventh Circuit · 2002
- Young v. CommissionerCourt of Appeals for the Eleventh Circuit · 1991
8 more not listed; retrieve them via the Exa API.