PARKS v. C. I. R.

No. 81-1221.

686 F.2d 408 (1982)

Haworth H. PARKS, et al., Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided August 13, 1982.


Attorney(s) appearing for the Case

John F. Murray, Acting Asst. Atty. Gen., Michael L. Paup, Jonathan S. Cohen, James F. Miller, Dept. of Justice, Tax Div., Washington, D. C., for respondent-appellant.

William Hance Lassiter, Jr., Laurence Papel, Nashville, Tenn., for petitioners-appellees.

Before KEITH and CONTIE, Circuit Judges, and PECK, Senior Circuit Judge.


ORDER

This appeal involves the single issue of whether the appellee taxpayers realized taxable income as a result of interest-free loans they received from a close corporation of which they were officers, directors, and shareholders.

The facts are stipulated. During the years 1972 to 1974, the corporation made loans to the taxpayers. No interest was charged and none was paid. There is no dispute that the loans were bona fide; the Commissioner did not seek...

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