WEGBREIT v. C.I.R.

No. 20-1306.

21 F.4th 959 (2021)

Samuel WEGBREIT and Elizabeth J. Wegbreit, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided December 29, 2021.


Attorney(s) appearing for the Case

John Edward Rogers , Attorney, Rogers & Associates, Evanston, IL, for Petitioners-Appellants.

Clint Carpenter , Bruce R. Ellisen , Attorneys, Department of Justice, Tax Division, Appellate Section, for Respondent-Appellee.

Before Sykes, Chief Judge, and Brennan and St. Eve, Circuit Judges.


Samuel and Elizabeth Wegbreit sheltered several million dollars of income in a life-insurance policy held by a sham trust. The IRS caught on to the Wegbreits' scheme and issued a deficiency notice showing that they owed millions in back taxes. The Wegbreits challenged the notice in the tax court. After discovery revealed a series...

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