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SUTTLE v. C. I. R.

No. 79-1385.

625 F.2d 1127 (1980)

Albert SUTTLE and Grace E. Suttle, Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Fourth Circuit.

Decided July 1, 1980.

Attorney(s) appearing for the Case

Jonathan S. Cohen, Tax Division, Dept. of Justice, Washington, D. C. (M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, and Helen A. Buckley, Tax Division, Dept. of Justice, Washington, D. C., on brief), for appellant.

James L. Sanderlin, Richmond, Va. (Carle E. Davis, Joseph C. Wool, Jr., McGuire, Woods & Battle, Richmond, Va., on brief), for appellees.

Before HALL and SPROUSE, Circuit Judges.

K. K. HALL, Circuit Judge:

The appellee, Albert Suttle, was the recipient of several interest-free loans from a closely-held corporation. The Commissioner of Internal Revenue (Commissioner) issued a notice of deficiency to Suttle and his wife1 for the economic value of the interest-free loans. The Tax Court found in favor of the Suttles, and the Commissioner appealed. We affirm.

During the tax years of 1972 and 1973, Albert Suttle...

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