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HORVAT v. C.I.R.

No. 77-1874.

671 F.2d 990 (1982)

George T. HORVAT and Carol R. Horvat, and James J. Minesal and Joyce Minesal, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided June 7, 1978.

Opinion March 8, 1982.

Attorney(s) appearing for the Case

George T. Horvat, West Allis, Wis., for petitioners-appellants.

Stuart E. Seigel, Chief Counsel, I.R.S., Washington, D. C., M. Carr Ferguson, Asst. Atty. Gen., Tax Div. Dept. of Justice, Gilbert E. Andrews, Chief Appellate Sec. Tax Div. Dept. of Justice, Skip I. Brennan, Atty. Main Just. Washington, D. C., for respondent-appellee.

Before CUMMINGS, Chief Judge, and PELL and WOOD, Circuit Judges.

PER CURIAM.

George and Carol Horvat and James and Joyce Minesal appeal from the decision of the United States Tax Court upholding certain income tax deficiencies determined by the Commissioner. Briefly, the Horvats and Minesals created trusts to which they assigned "the exclusive use of my lifetime services and all resultant earned remuneration." The Tax Court held that this conveyance was merely an anticipatory assignment of income and as such, under Lucas v....

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