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Dickman Vs. Commissioner
Cites for this judgment
- US Supreme Court
- Feb 22, 1984
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U.S. 330 (1984) U.S. Supreme Court Dickman v. CommissionerSearch
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U.S. 330 (1984) Dickman v. CommissionerSearch
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here, sought redetermination of the deficiencies in the Tax Court. Reaffirming its earlier decision in Crown v. CommissionerSearch
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squarely rejected the contrary position adopted by the United States Court of Appeals for the Seventh Circuit in Crown v. CommissionerSearch
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several prior occasions, this Court has acknowledged the expansive sweep of the gift tax provisions. In Commissioner v. WemyssSearch
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Passailaigue v. UnitedSearch
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Catalano, Inc. v. TargetSearch
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and regulations to authorize the levying of a gift tax on the value of the use of money or property. See Crown v. CommissionerSearch
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Johnson v. UnitedSearch
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may change an earlier interpretation of the law, even if such a change is made retroactive in effect. E.g., Dixon v. UnitedSearch
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rule applies even though a taxpayer may have relied to his detriment upon the Commissioner's prior position. Dixon v. UnitedSearch
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Bob Jones University v. UnitedSearch
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Brief any citation in this list with AI Studio
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Cf. Diedrich v. CommissionerSearch
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interpreted to include all forms of income except those specifically excluded from its reach. See, e.g., Commissioner v. GlenshawSearch
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a fair rate of interest, followed by a gift from the lender to the borrower in the amount of that interest. See Crown v. CommissionerSearch
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Barker v. Publishers'Search
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between 1971 and 1976. The Commissioner first litigated the question of the gift taxability of such loans in Johnson v. UnitedSearch
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that an interest-free loan would have tax consequences. The IRS first pursued its present position in 1966 in Johnson v. UnitedSearch
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Rul. 73-61, 1973-1 Cum.Bull. 408. In 1977, the Commissioner first raised the issue before the Tax Court in Crown v. CommissionerSearch
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free loans. Congress is the body that is best equipped to determine the rules that should govern. United States v. ByrumSearch
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Commissioner v. BrownSearch
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In United States v. ByrumSearch
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income tax consequences to interest-free loans in the absence of congressional action on the subject. See Hardee v. UnitedSearch
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Parks v. CommissionerSearch
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Baker v. CommissionerSearch
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Commissioner v. GreenspunSearch
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Beaton v. CommissionerSearch
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Martin v. CommissionerSearch
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Suttle v. CommissionerSearch
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In Johnson v. UnitedSearch
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In Crown v. CommissionerSearch
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n. 4 (CA11 1982). The Service has urged yet another method in a recently docketed Tax Court case, LaRosa v. CommissionerSearch
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unfair that it would constitute an abuse of the Commissioner's discretion. See Central Illinois Public Service Co. v. UnitedSearch
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U.S. Supreme Court Dickman v. CommissionerSearch
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Crown v. CommissionerSearch
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In Commissioner v. WemyssSearch
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See Crown v. CommissionerSearch
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E.g., Dixon v. UnitedSearch
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Dixon v. UnitedSearch
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Bob Jones University v. UnitedSearch
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Commissioner v. GlenshawSearch
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Barker v. Publishers'Search
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United States v. ByrumSearch
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See Hardee v. UnitedSearch
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LaRosa v. CommissionerSearch
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See Central Illinois Public Service Co. v. UnitedSearch
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