Tax Court in Brief | Deitch v. Comm’r; and Barry v. Comm’r | Deductible Interest Under IRC 163

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The Tax Court in Brief – August 22nd – August 26th, 2022

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

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Tax Litigation:  The Week of August 22nd, 2022, through August 26th, 2022

Alexander C. Deitch v. Comm’r, No. 21282-17; and Jonathan D. Barry and Susan S. Barry v. Comm’r, No. 21283-17, T.C. Memo 2022-86 | August 25, 2022 | Gustafson |

Key Issues:

Facts and Primary Holdings

Key Points of Law:


Where, as here, parties to a transaction have clearly established the terms of their agreement, a debtor-creditor relationship is not going to be reclassified as an equity investment without evidence that simply didn’t exist here.