Legal Opinion

Foglesong v. Commissioner

Court of Appeals for the Seventh Circuit

Decided October 29, 1982No. 82-1266PublishedCited by 14 opinions

1Opinion of the Court

PELL, Circuit Judge..

Appellant Frederick H. Foglesong (taxpayer) 1 appeals from a decision of the United States Tax Court assessing deficiencies in income taxes for four taxable years. The Tax Court held that the Commissioner of Internal Revenue could properly allocate the income received by the taxpayer’s personal service corporation to the taxpayer pursuant to 26 U.S.C. § 482.2

The case arose in 1973 when the Commissioner sent tax deficiency notices to the taxpayer, which he contested. The Tax Court, on September 20, 1976, ruled that most of the income reported by the corporation should have…

2Cases cited14 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. Ach v. CommissionerUnited States Tax Court · 1964
  3. Rubin v. CommissionerUnited States Tax Court · 1971
  4. Richard Rubin and Helene Rubin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1972
  5. Richard Rubin and Helene Rubin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970

9 more not listed; retrieve them via the Exa API.

3Cited by14 opinions

  1. Haag v. CommissionerUnited States Tax Court · 1987
  2. Spencer D. Stewart, Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
  3. Eli Lilly & Co. v. CommissionerUnited States Tax Court · 1985
  4. Margaret Gay, Laura Kuykendall, Ruby Williams v. Louis W. Sullivan, M.D., Secretary of United States Department of Health and Human ServicesCourt of Appeals for the Seventh Circuit · 1992
  5. Frederick H. Foglesong and Elizabeth C. Foglesong v. Commissioner of Internal Revenue, Frederick H. Foglesong Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1983

9 more not listed; retrieve them via the Exa API.

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