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CROWN v. C. I. R.

No. 77-1898.

585 F.2d 234 (1978)

Lester CROWN, Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Seventh Circuit.

Decided September 19, 1978.

Rehearing and Rehearing Denied November 30, 1978.

Attorney(s) appearing for the Case

M. Carr Ferguson, Asst. Atty. Gen., Tax Dept., Dept. of Justice, Washington, D. C., for respondent-appellant.

Byron S. Miller, Chicago, Ill., for petitioner-appellee.

Before SPRECHER and WOOD, Circuit Judges, and VAN PELT, Senior District Judge.

Rehearing and Rehearing En Banc Denied November 30, 1978.

HARLINGTON WOOD, Jr., Circuit Judge.

The primary question presented in this appeal is whether a taxpayer who lends money to his children and other close family members in the form of no-interest loans and open accounts payable on demand must include in the computation of gifts taxable during a particular tax year the value of the interest foregone on the indebtedness...

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