Legal Opinion
Commissioner of Internal Revenue v. Herman M. Greenspun and Barbara J. Greenspun
Court of Appeals for the Ninth Circuit
Decided February 24, 1982No. 79-7624PublishedCited by 15 opinions
1Opinion of the Court
TANG, Circuit Judge:
Herman M. Greenspun received a loan at a three percent interest rate when the prevailing market rate was six percent. The Commissioner of Internal Revenue (Commissioner) determined deficiencies in Green-spun’s 1967 and 1969 federal income taxes on the theory that Greenspun had realized gross income in an amount equal to the economic value between the market rate of interest and the actual interest rate on his loan. The Tax Court found in favor of Greenspun, 72 T.C. 931 (1979). We affirm.
I
Facts
The facts in this case are undisputed and are fully chronicled in the Tax Court’s…
2Cases cited9 opinions
- United States v. ByrumSupreme Court of the United States · 1972
- Dean v. CommissionerUnited States Tax Court · 1961
- Greenspun v. CommissionerUnited States Tax Court · 1979
- Albert Suttle and Grace E. Suttle v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1980
- Zager v. CommissionerUnited States Tax Court · 1979
4 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Huff v. CommissionerUnited States Tax Court · 1983
- W.L. Hardee and Elnora L. Hardee v. The United StatesCourt of Appeals for the Federal Circuit · 1983
- Jack and Florence Baker v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1982
- Kelly B. Niles, by and Through His Co-Conservators, David F. Niles and Joan A. MacMahon v. United StatesCourt of Appeals for the Ninth Circuit · 1983
- Haworth H. Parks v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1982
10 more not listed; retrieve them via the Exa API.