Legal Opinion

Diane S. Blodgett v. Commissioner of Internal Revenue

Court of Appeals for the Eighth Circuit

Decided January 12, 2005No. 03-3917PublishedCited by 112 opinions

1Opinion of the Court

BYE, Circuit Judge.

Diane Blodgett, a special education teacher, appeals from a tax court determination in favor of the Internal Revenue Service. We affirm.

I

We adopt the facts as set forth in the tax court’s opinion, T.C.M.2003-212 (2003), and simply restate some critical facts so as to make understandable the legal issues presented herein. In the 1970’s, Ms. Blod-gett’s ex-husband Michael Blodgett founded T.G. Morgan, Inc., a business engaged in the buying and selling of rare coins. The enterprise began as a sole proprietorship, later incorporated, utilizing a sub-chapter S election…

2Cases cited19 opinions

  1. United States v. OlanoSupreme Court of the United States · 1993
  2. Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
  3. The Limited, Inc., and Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2002
  4. United States v. Richard Alan TulkCourt of Appeals for the Eighth Circuit · 1999
  5. Greenbaum v. United StatesCourt of Appeals for the Ninth Circuit · 1935

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3Cited by112 opinions

  1. Knudsen v. Comm'rUnited States Tax Court · 2008
  2. Whitehouse Hotel Ltd. Partnership v. CommissionerCourt of Appeals for the Fifth Circuit · 2010
  3. Estate of Bongard v. Comm'rUnited States Tax Court · 2005
  4. Greenspan v. LADT LLCCalifornia Court of Appeal · 2010
  5. Wilmington Trust Co. v. AMR Corp. (In re AMR Corp.)District Court, S.D. New York · 2013

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

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