Tanner v. Commissioner
United States Tax Court
45 T.C.M. 1419 (1983), T.C. Memo. 1983-230
- Written by Matthew Celestin, JD
Facts
Ray Tanner, Jr. and Patricia Tanner (plaintiffs) were minority shareholders of Ray Tanner Motors, Inc. (the corporation). Roy was the vice president of the corporation. During 1977 and 1978, the corporation provided the Tanners with three company vehicles for personal use. The corporation paid all maintenance and other fees associated with the vehicles and was never reimbursed for these expenses. The corporation sold each vehicle following the Tanners’ use, and all profits from the sales were included in the corporation’s earnings and profits. The corporation’s earnings and profits during 1977 and 1978 were at least equal to the fair market value of the Tanners’ use of the vehicles. The Commissioner of Internal Revenue (the Commissioner) (defendant) determined that the Tanners’ use of the vehicles constituted constructive dividends and was therefore taxable as income. The Commissioner assessed a deficiency based on the fair market value of the Tanners’ use of the vehicles.
Rule of Law
Issue
Holding and Reasoning (Wiles, J.)
What to do next…
Here's why 899,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 47,000 briefs, keyed to 994 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.
