Diane S. Blodgett v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
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
- United States v. OlanoSupreme Court of the United States · 1993
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- The Limited, Inc., and Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2002
- United States v. Richard Alan TulkCourt of Appeals for the Eighth Circuit · 1999
- Greenbaum v. United StatesCourt of Appeals for the Ninth Circuit · 1935
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- Wilmington Trust Co. v. AMR Corp. (In re AMR Corp.)District Court, S.D. New York · 2013
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