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FOGLESONG v. C. I. R.

No. 82-1266.

691 F.2d 848 (1982)

Frederick H. FOGLESONG and Elizabeth C. Foglesong, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. FREDERICK H. FOGLESONG CO., INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided October 29, 1982.

Opinion on Denial of Rehearing and Rehearing January 20, 1983.

Attorney(s) appearing for the Case

James J. Shrager, Hannoch, Weisman, Stern, Besser, Berkowitz & Kinney, P.A., Newark, N.J., for petitioners-appellants.

Jonathan Cohen, Asst. Atty. Gen., Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

The Honorable Edward Dumbauld, Senior District Judge of the Western District of Pennsylvania, sitting by designation.

Opinion on Denial of Rehearing and Rehearing En Banc January 20, 1983.

PELL, Circuit Judge.

Appellant Frederick H. Foglesong (taxpayer)1 appeals from a decision of the United States Tax Court assessing deficiencies in income taxes for four taxable years. The Tax Court held that the Commissioner of Internal Revenue could properly allocate the income received by the taxpayer's personal service corporation to the taxpayer pursuant...

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