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Dean v. Commissioner
United States Court of Appeals for the Third Circuit
187 F.2d 1019 (1951)
- Written by Sara Rhee, JD
Facts
Junius Simpson Dean (plaintiff) and his wife owned and occupied property. They were also the sole shareholders of Nemours Corporation, and Dean was the corporation's president. In 1931, the couple transferred the property to the corporation, but they continued to live on the property after the transfer. The Commissioner of Internal Revenue (defendant) determined that Dean owed income taxes on the rental value of the property. Dean and his wife petitioned the Tax Court for review of the Commissioner's determination. The Tax Court ruled in the Commissioner’s favor, and the couple appealed to the United States Court of Appeals for the Third Circuit.
Rule of Law
Issue
Holding and Reasoning (Goodrich, J.)
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