Albert Suttle and Grace E. Suttle v. Commissioner of Internal Revenue

K. K. HALL, Circuit Judge:

The appellee, Albert Suttle, was the recipient of several interest-free loans from a closely-held corporation. The Commissioner of Internal Revenue (Commissioner) issued a notice of deficiency to Suttle and his wife 1 for the economic value of the interest-free loans. The Tax Court found in favor of the Suttles, and the Commissioner appealed. We affirm.

During the tax years of 1972 and 1973, Albert Suttle owned 65 percent of the outstanding stock of Master Chevrolet Sales, Incorporated (Master). The balance of the outstanding stock was owned by Suttle’s son and two…