Jack and Florence Baker v. Commissioner of Internal Revenue

The Commissioner of Internal Revenue appeals a decision of the United States Tax Court, Arnold Raum, Judge, holding that taxpayer Jack Baker did not realize income as a result of interest-free loans from Sue Brett, Inc., a corporation owned wholly by taxpayer, his wife, and their children. Baker v. Commissioner, 75 T.C. 166 (1980). The Commissioner had issued a notice of deficiency determining that taxpayer realized unreported taxable income totalling $15,416 for the years 1973 through 1975. This amount represented the interest taxpayer would have had to pay on his average yearly loans from…