Study Aids
Case Briefs Overview
Casebooks
Case Briefs
S

Stanley v. Commissioner

T.C. Memo. 2003–97 (2003)

From our private database of 47,100+ case briefs, written and edited by humans—never with AI.

Stanley v. Commissioner

United States Tax Court
T.C. Memo. 2003–97 (2003)

Facts

Clifton Stanley (plaintiff) owned and operated Stanley & Associates, a sole proprietorship engaged in insurance sales, retirement advice, and real estate investment. In 2010 and 2011, Stanley received loans from clients and friends. He offered attractive returns and intended to repay the loans, including interest, using proceeds from his insurance and real estate activities. Stanley issued 22 promissory notes totaling $302,000 in 2010 and $399,000 in 2011. The notes detailed the loan amounts, relevant dates, lender information, interest rates (ranging from 7 to 25 percent), loan terms (ranging from six to 24 months), and repayment terms. All but one note was unsecured. Stanley made interest payments on the loans; some were timely, while others were late. When the loans became due, some were paid in full, and others were renewed with extended terms and continued interest accrual. Stanley did not report the loan proceeds on his 2010 and 2011 federal income tax returns. The commissioner of the Internal Revenue Service (defendant) assessed deficiencies, asserting that the purported loan proceeds were actually taxable income. Stanley challenged the commissioner’s determination in tax court.

Rule of Law

Issue

Holding and Reasoning (Pugh, 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 905,000 law students since 2011. Some law schools 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 905,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 47,100 briefs, keyed to 995 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 905,000 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
  • 47,100 briefs - keyed to 995 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

Key Terms