Lester Crown v. Commissioner of Internal Revenue

HARLINGTON WOOD, Jr., Circuit Judge.

The primary question presented in this appeal is whether a taxpayer who lends money to his children and other close family members in the form of no-interest loans *235and open accounts payable on demand must include in the computation of gifts taxable during a particular tax year the value of the interest foregone on the indebtedness outstanding during that year. The tax court ruled in favor of the taxpayer’s argument that no taxable gift occurred. We affirm.

As the relevant facts have been set out in the Tax Court’s opinion in this case reported at 67 T.C.…