Document Type

Article

Publication Date

1965

Publication Title

George Washington Law Review

Keywords

salary indebtedness, tax liability, tax law

Abstract

This article discusses C.I.R. v. Fender Sales, Inc., 338 F. 2d 924 (9th Cir. 1964). The author concludes that by taxing at ordinary rates the benefit realized by respondents when they invested the income in the corporation which they owned in exchange for its stock, the court eliminated the possibility--suggested by the dissent--of any undeserved capital gains treatment. The case serves to reinforce the fait accompli in the tax law between the treatment of ordinary income and capital transactions.

Comments

Link to a copy on HeinOnline -Available at your institution, remotely via their proxy server or via password.

Volume

33

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