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BERGERSEN v. C.I.R.

No. 96-1730.

109 F.3d 56 (1997)

Earl O. BERGERSEN and Evelyn K. Bergersen, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, First Circuit.

Decided March 21, 1997.

Attorney(s) appearing for the Case

James M. O'Brien with whom Baker & McKenzie was on briefs for petitioners.

Jonathan S. Cohen with whom Loretta C. Argrett, Assistant Attorney General, and Frank P. Cihlar, Tax Division, Department of Justice, were on brief for respondent.

Before SELYA, Circuit Judge, BOWNES, Senior Circuit Judge, and BOUDIN, Circuit Judge.

BOUDIN, Circuit Judge.

This appeal involves a tax dispute posing two questions: whether certain payments to the taxpayers by a controlled company were constructive dividends (rather than loans) and whether the taxpayers were residents of Illinois (rather than Puerto Rico) in 1986 and 1987. The Tax Court answered yes to both questions, resulting in adverse consequences for the taxpayers, who now appeal. We affirm the Tax Court.

The basic facts, derived from...

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