Bobby E. Welch and Kathleen Newman v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• explaining that the taxpayer must establish that income resulted from a nontaxable loan and setting forth factors for determining whether a transaction is a loan
• noting that a purported lender’s failure to seek repayment is inconsistent with the existence of a bona fide loan
• stating that factors relevant in assessing whether a transaction is a true loan are: “(1) whether the promise to repay is evidenced by a note or other instrument; (2) whether interest was charged; (3) whether a fixed schedule for repayments was established; (4
• examining factors necessary to determine whether a transaction constitutes a bona fide loan
• examining factors necessary to determine whether a transaction constitutes a bona fide loan
• deposits are prima facie evidence of income, and it is taxpayer’s burden to prove they are not taxable

Source: CourtListener parenthetical corpus (CC0).