Wales v. Commissioner
United States Tax Court
In 1968, P's parents transferred $4,000 to him, and he promised to repay them $8,000 in the future. During 1971 and 1972, P paid his mother approximately $5,000. In Jan. 1973, P's mother transferred to him an additional $5,000, and in that year, he paid her approximately $3,500. Held, P is not entitled to deduct as interest under sec. 163(a), I.R.C. 1954, any part of the payments to his mother.
1Opinion of the Court
HAROLD W. WALES and DOROTHY K. WALES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Wales v. Commissioner
Docket No. 1103-76.
United States Tax Court
T.C. Memo 1978-125; 1978 Tax Ct. Memo LEXIS 384; 37 T.C.M. (CCH) 550; T.C.M. (RIA) 78125;
March 30, 1978, Filed
In 1968, P's parents transferred $4,000 to him, and he promised to repay them $8,000 in the future. During 1971 and 1972, P paid his mother approximately $5,000. In Jan. 1973, P's mother transferred to him an additional $5,000, and in that year, he paid her approximately $3,500. Held, P is not entitled to deduct as interest…
2Cases cited37 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Helvering v. TaylorSupreme Court of the United States · 1935
- Knetsch v. United StatesSupreme Court of the United States · 1960
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