Galli v. Commissioner: Applicable Federal Rate (AFR) – A FMV Proxy?
Estate of Galli v. Comm’r, T.C., No. 7003‑20 and 7005‑20 involves an intra‑family loan that the Court determined was a valid, interest‑bearing obligation rather than a disguised gift, recognizing that a note issued at the Applicable Federal Rate (AFR) with proper documentation and timely interest payments can be respected as a bona fide loan while…


