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FURLONG v. C.I.R.

No. 93-3668.

36 F.3d 25 (1994)

Ralph D. FURLONG and Jacqueline L. Furlong, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided September 19, 1994.

Attorney(s) appearing for the Case

Patrick B. Mathis (argued), Kevin J. Richter, Mathis, Marifian, Richter & Grandy, Belleville, IL, for petitioners-appellants.

Richard Farber, Gary R. Allen, Steven W. Parks, Thomas J. Clark (argued), Dept. of Justice, Tax Div. Appellate Section, Charles S. Casazza, U.S. Tax Court, Washington, DC, for respondent-appellee.

Before SPROUSE, COFFEY, and KANNE, Circuit Judges.

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...

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