Quimbee logo
DMCA.com Protection Status

Gehl v. Commissioner

50 F.3d 12 (1995)

Case BriefRelatedOptions
From our private database of 26,900+ case briefs...

Gehl v. Commissioner

United States Court of Appeals for the Eighth Circuit

50 F.3d 12 (1995)

Facts

James and Laura Gehl (plaintiffs) could no longer repay a loan for which their farm provided collateral. To restructure the loan, the Gehls transferred most of the farm’s land to their lender, who provided an excess valuation by assessing the value of the land at far more than the Gehls’ adjusted basis in the land. The lender reduced the Gehls’ loan balance accordingly. Subsequently, the lender forgave the remaining balance as a write-off. The commissioner of internal revenue (commissioner) (defendant) treated the write-off as tax-exempt income from the discharge of indebtedness. However, the commissioner determined that the excess valuation was a taxable gain. The Gehls filed a petition challenging the commissioner’s determination. The Gehls contended that because they used both the write-off and the excess valuation solely to repay the loan, and remained insolvent after they did so, both the write-off and the excess valuation were tax-exempt. The tax court ruled against the Gehls, who appealed.

Rule of Law

Issue

Holding and Reasoning (Bogue, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 541,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 541,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 26,900 briefs, keyed to 983 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 541,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 26,900 briefs - keyed to 983 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership