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BLODGETT v. C.I.R.

No. 03-3917.

394 F.3d 1030 (2005)

Diane S. BLODGETT, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: January 12, 2005.

Attorney(s) appearing for the Case

Counsel who presented argument on behalf of the appellant was Denial W. Schermer of Minneapolis, MN.

Counsel who presented argument on behalf of the appellee was Samuel A. Lambert, Tax Div., Dept. of Justice, Washington, D.C. Kenneth L. Greene of the Tax Div., DOJ appeared on the brief.

Before BYE, LAY, and GRUENDER, Circuit Judges.

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. Blodgett's ex-husband Michael Blodgett founded...

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