Does the Commissioner have any authority or authority to levy taxes on funds received without any contemporaneous recognition of the obligation to repay?
MultiRegion, United States of America
The following excerpt is from Gilbert v. C. I. R., 552 F.2d 478 (2nd Cir. 1977):
8 Quinn v. Commissioner, supra at 619, 623-25, relied on by the Commissioner, involved taxation of funds received without any contemporaneous recognition of the obligation to repay, and it is therefore distinguishable from the present case.
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