Summary
At issue is the taxpayers arguement that their use of the six percent safe harbor rate under I.R.C. 483 prevents the IRS from using the prevailing market interest rate to determine the dis ...
See Also
'Safe Harbor Rate' Not Adequate to Present Value Note for Gift Taxes; Circuits Disagree on Issue
Taxpayer transferred assets in return for a promissory note bearing interest at the then current "safe harbor" interest rate, which was below the prevailing market rate.