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Dickman v. Commissioner

465 U.S. 330 (1984)

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Dickman v. Commissioner

United States Supreme Court

465 U.S. 330 (1984)

Facts

Between 1971 and 1976, husband and wife Paul and Esther Dickman loaned large amounts of money to their son Lyle Dickman and the family business. Most of the loans were memorialized in interest-free demand notes. Paul died in 1976, leaving a sizable estate. The commissioner of internal revenue (defendant) determined that the loans were in fact gifts subject to taxation. The commissioner did not seek to tax the loan principal itself but rather the reasonable value of the use of the money loaned and issued tax-deficiency notices to Paul’s estate and Esther (plaintiffs). The United States Tax Court held that interest-free family loans do not result in taxable gifts, and the Eleventh Circuit reversed. The estate and Esther filed a petition for certiorari.

Rule of Law

Issue

Holding and Reasoning (Burger, C.J.)

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