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DICKMAN v. C. I. R.

No. 81-5297.

690 F.2d 812 (1982)

Esther C. DICKMAN, Estate of Paul B. Dickman, Deceased, G. Wendell Smith, Personal Representative, Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Eleventh Circuit.

Certiorari Granted February 22, 1983.

Attorney(s) appearing for the Case

John F. Murray, Acting Asst. Atty. Gen., Michael L. Paup, Chief, Appellate Section, John H. Menzel, Director, Tax Litigation Div., Farley Katz, Atty., Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellant.

Frank P. Riggs, Sun City Center, Fla., Guy S. Emerich, Punta Gorda, Fla., for petitioners-appellees.

Before GODBOLD, Chief Judge, HILL and FAY, Circuit Judges.

JAMES C. HILL, Circuit Judge:

At issue in this case is whether taxable gifts resulted when lenders made interest-free loans to a relative and to a closely held corporation. The Tax Court ruled that all loans here were on a demand basis and, following its decision in Crown v. Commissioner, 67 T.C. 1060 (1977), aff'd, 585 F.2d 234 (7th Cir. 1978), it held that the loans involved no gift...

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