Legal Opinion
Martin v. Commissioner
Court of Appeals for the Fifth Circuit
Decided July 6, 1981No. Nos. 80-1200, 80-3135 and 80-5084PublishedCited by 13 opinions
1Opinion of the Court
TATE, Circuit Judge:
In Dean v. Commission, 35 T.C. 1083 (1961), the Tax Court held that the use of funds from an interest-free loan to a taxpayer did not constitute a taxable benefit. The Commissioner’s present appeals are his latest effort to secure an overruling or modification of the Dean rationale, which the Tax Court followed in the present cases, in its holding that the interest-free loans did not result in taxable income herein. Despite the persuasive reasons offered by the dissenting views, we are unwilling to disturb Dean, at this late date, and we therefore affirm.
The logical…
2Cases cited2 opinions
- Dean v. CommissionerUnited States Tax Court · 1961
- Albert Suttle and Grace E. Suttle v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1980
3Cited by13 opinions
- Colin F. And Eleanor M. Beaton v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1981
- Commissioner of Internal Revenue v. Herman M. Greenspun and Barbara J. GreenspunCourt of Appeals for the Ninth Circuit · 1982
- Esther C. Dickman, Estate of Paul B. Dickman, Deceased, G. Wendell Smith, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1983
- Jack and Florence Baker v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1982
- Rountree Cotton Co. v. Comm'rUnited States Tax Court · 1999
8 more not listed; retrieve them via the Exa API.