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HAGY v. U.S.

Civ. A. No. 88-0060-A.

778 F.Supp. 897 (1991)

George W. HAGY, et al., Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, W.D. Virginia, Abingdon Division.

September 5, 1991.

Attorney(s) appearing for the Case

Eric D. Whitesell, Tazewell, Va., for plaintiffs.

Jerry W. Kilgore, Asst. U.S. Atty., and David Hickman, Washington, D.C., for U.S.

MEMORANDUM OPINION

WILSON, District Judge.

This is a refund suit under 26 U.S.C. § 7422 for the tax year 1980 by plaintiffs, George W. Hagy ("Hagy") and his wife, for income taxes and a negligence penalty Hagy and his wife paid on insurance commissions following an assessment for those amounts. Hagy and his wife maintain that the commissions were not income to Hagy but to his wholly owned corporation, the George W. Hagy Insurance Agency, Inc. ("Hagy...

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