Cohen v. Commissioner
United States Tax Court
P made interest-free demand loans to family trusts. Held, R's method of valuing the gifts made to the trusts reflects the reasonable value of the use of the money lent. Dickman v. Commissioner, 465 U.S. 330 (1984).
1Opinion of the Court
OPINION
WILLIAMS, Judge:
The Commissioner determined deficiencies in petitioner’s Federal gift tax in the following taxable periods and amounts:
Calendar period ending Deficiency
Sept. 30, 1980. $15,599
Dec. 31, 1980. 19,782
Mar. 31, 1981 . 20,515
Jun. 30, 1981. 30,096
Sept. 30, 1981 . 32,379
Dec. 31, 1982. 75,140
Dec. 31, 1983. 142,033
Dec. 31, 1984. 2,954
Total deficiencies. 338,498
The issue we must decide is the appropriate interest rate to use in valuing the gift that results from an interest-free demand loan pursuant to Dickman v. Commissioner, 465 U.S. 330 (1984).
The facts of this case have been…
2Cases cited8 opinions
- Dickman v. CommissionerSupreme Court of the United States · 1984
- White v. AronsonSupreme Court of the United States · 1937
- Lester Crown v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1978
- Goldstein v. CommissionerUnited States Tax Court · 1987
- Crown v. CommissionerUnited States Tax Court · 1977
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3Cited by15 opinions
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- Peter E.C. Muserlian, Theodora Muserlian and Peter Muserlian v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Melvin S. Cohen, Eileen D. Cohen and Edith Phillips v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1990
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