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CROWN v. COMMISSIONER

Docket No. 9192-74.

67 T.C. 1060 (1977)

LESTER CROWN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 31, 1977.

Attorney(s) appearing for the Case

Byron S. Miller, for the petitioner.

Seymour I. Sherman, for the respondent.

OPINION

DAWSON, Chief Judge:

Respondent determined a deficiency of $46,084.54 in petitioner's Federal gift tax for the year 1967.

The issue presented for decision is whether interest-free loans to relatives of the lender (or trusts for the benefit of such relatives) give rise to taxable gifts from the lender to the borrowers to the extent of the value of the use of the funds loaned; and, if so, what is the proper measure of the amount of such...

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