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NOTES 623 Tax Lawyer, Vol. 55, No. 2 NOTE GIFT OR SALE? A QUESTION OF INTENT IN ESTATE OF COSTANZA V. COMMISSIONER In the recently decided case Estate of Costanza v. Commissioner,1 the Tax Court held that intrafamily transfers are presumed to be gifts absent convincing evidence to the contrary.2 This case involved the transfer of real property betwwee the taxpayer and his son in exchange for a self-canceling installment note (SCIN).3 Following mixed precedent, Costanza held that courts should...

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