id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-2695	Benjamin, Jay D.	The Safe-Harbor Interest Rates Under Section 483 of the Internal Revenue Code: A Gift Tax Trap	1987	30	.pdf	application/pdf	13328	843	74	§ 25.2512-8 (1958). 1987] GIFT TAX TRAP 685 However, if market interest rates are used to value the consideration received by the seller for gift tax purposes, the gift would be computed as follows: Fair market value of property $6000 Less: Value of consideration discounted us- ing a nine percent interest rate [$2245 x 2.531340 =] $5683 Value of gift41 $317 Thus, even if the section 483 interest rate is used to calculate the payments to be received by the seller, a taxable gift will be computed if a higher market interest rate should have been used to value the consideration received by the seller for gift tax purposes. B. Ballard v. Commissioner Ballard v. Commissioner*2 a recently decided United States Tax Court case, illustrates the inequities that result when section 483 applies to a transaction and when market interest rates are used to compute a taxable gift because related parties are involved.	cache/inlawrev-2695.pdf	txt/inlawrev-2695.txt