Legal Opinion

Sargent v. Commissioner

Court of Appeals for the Eighth Circuit

Decided April 2, 1991No. 90-1782PublishedCited by 24 opinions

1Opinion of the Court

BOGUE, Senior District Judge.

This case, on appeal from the United States Tax Court, is one of first impression for this Court. Initially, the Commissioner of Internal Revenue issued Notices of Deficiency with respect to the federal income *1254taxes of Gary A. Sargent1 for the years 1978 through 1981; and for Steven M. Christoff2 for the years 1980 through 1982.

Sargent and Christoff (hereinafter “Appellants”) were hockey players with the Minnesota North Stars Hockey Club (hereinafter the “Club”). Appellants’ personal service corporations (PSC), created to represent the business associations of…

2Cases cited17 opinions

  1. United States v. Winston Bryant McConneyCourt of Appeals for the Ninth Circuit · 1984
  2. Commissioner v. DubersteinSupreme Court of the United States · 1960
  3. Lucas v. EarlSupreme Court of the United States · 1930
  4. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  5. Achiro v. CommissionerUnited States Tax Court · 1981

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

3Cited by24 opinions

  1. Donaldson Co., Inc. v. Burroughs Diesel, Inc.Court of Appeals for the Eighth Circuit · 2009
  2. Leavell v. CommissionerUnited States Tax Court · 1995
  3. Black Hills Corporation, Doing Business as Black Hills Power and Light Company and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1996
  4. Douglas Page v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1995
  5. 20 Employee Benefits Cas. 1391, Pens. Plan Guide P 23921s Berger Transfer & Storage v. Central States, Southeast and Southwest Areas Pension Fund Central States, Southeast and Southwest Areas Health and Welfare Fund Marion Winstead, Trustee of Said Funds Robert Sansone, Trustee of Said Funds R. Jerry Cook, Trustee of Said Funds Harold D. Leu, Trustee of Said Funds Howard McDougall Trustee of Said Funds Robert Baker, Trustee of Said Funds R v. Pulliam, Trustee of Said Funds Arthur H. Bunte, Jr., Trustee of Said FundsCourt of Appeals for the Eighth Circuit · 1996

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