Legal Opinion

Ralph D. Furlong and Jacqueline L. Furlong v. Commissioner of Internal Revenue

Court of Appeals for the Seventh Circuit

Decided September 19, 1994No. 93-3668PublishedCited by 12 opinions

1Opinion of the Court

KANNE, Circuit Judge.

Ralph Furlong was the president and sole shareholder of Wire Industries, Inc., a corporation doing business in Illinois. Furlong was also a participant in Wire Industries’ pension plan. On August 25, 1982, Furlong borrowed $99,000 from his pension plan. Furlong signed a promissory note, requiring him to repay the principal amount of the loan plus an initial interest rate of twelve percent per year. Furlong and his wife Jacqueline did not include the loan proceeds as taxable income on their 1982 joint income tax return.

On May 29, 1990, the Commissioner of Internal Revenue…

2Cases cited13 opinions

  1. Federal Communications Commission v. Beach Communications, Inc.Supreme Court of the United States · 1993
  2. Pension Benefit Guaranty Corporation v. RA Gray & Co.Supreme Court of the United States · 1984
  3. Nichols v. CoolidgeSupreme Court of the United States · 1927
  4. Welch v. HenrySupreme Court of the United States · 1938
  5. Blodgett v. HoldenSupreme Court of the United States · 1927

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3Cited by12 opinions

  1. Davon, Inc. v. ShalalaCourt of Appeals for the Seventh Circuit · 1996
  2. Tate & Lyle, Inc. v. CommissionerUnited States Tax Court · 1994
  3. Davon, Inc. v. ShalalaCourt of Appeals for the Seventh Circuit · 1996
  4. Rivers v. StateSupreme Court of South Carolina · 1997
  5. Palmer v. LOUISIANA FORESTRY COM'NSupreme Court of Louisiana · 1997

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