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DICKMAN v. COMMISSIONER

No. 82-1041.

465 U.S. 330 (1984)

104 S.Ct. 1086

79 L.Ed.2d 343

DICKMAN ET AL. v. COMMISSIONER OF INTERNAL REVENUE

Supreme Court of United States.

Decided February 22, 1984

Attorney(s) appearing for the Case

Frank P. Riggs argued the cause for petitioners. With him on the briefs were Guy S. Emerich, Vester T. Hughes, Jr., M. David Bryant, Jr., and Kathryn G. Henkel.

Deputy Solicitor General Wallace argued the cause for respondent. With him on the brief were Solicitor General Lee, Assistant Attorney General Archer, Harriet S. Shapiro, Michael L. Paup, Jonathan S. Cohen, and Farley P. Katz.*

CHIEF JUSTICE BURGER delivered the opinion of the Court.

We granted certiorari to resolve a conflict among the Circuits as to whether intrafamily, interest-free demand loans result in taxable gifts of the value of the use of the money lent.

I

A

Paul and Esther Dickman were husband and wife; Lyle Dickman was their son. Paul, Esther, Lyle, and Lyle's wife and children were the owners of Artesian...

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