Discuss how the following court case illustrates how the courts, through judicially enunciated doctrines, impact the interpretation of tax law. Charles E Wolfe w 612 F. Supp 605 (DC Mont, 1985) aff d. 798 F.2d 1241 (9th Cir, 1986). Follow the format of the Case Brief Example on blackboard and include: Facts Issue Decision Reasons for Decision Solution Facts: Wolfe & E company\'s into truck trailer lease , the sole shareholder and president is Mr.Wolfe , he is also the proprietorship of other \" on the road business\" under the name of Charles .e. wolfe d/b/a Evergreen express.Wolfe did not have a seperate bank account for the corporation , also he paid all the wages and salraies form the proprietorship account while claiming the expenses under the corpoeration Issue : the wolfe Corporation incurred a federal tax liability of $114,472.91 for employment , fuel and highway use taxes and for penalties fees and interest.Wolfe paid the tax after ICC was laid on him but he contended that Service cannot look into his personal property for payment if the tax due.However IRS stated since corporation was alter ego of the Wolfe Decision : It was decided that corporation was the alter ego of the Wolfe, thus justifying the piercing of viel. Reasons for Decision: The wolfe did not maintain a seperate bank account , also he paid salary and wages of the employees form the proprietorship,also wolfe was the sole shareholder and president of the corporation,He did not consulted other directors for decision making.his personal funds are premingled with corporations.His and corporations credit are used interchangebaly to acquire loans, they are in the same business,sharing same address, wolfe admits to third parties that they are one and the same, corporations income is distributed through other means than diividends. thus corporation and shareholder share common identity, thus it was proper for the service to look into his personal property. .

1. Discuss how the following court case illustrates how the courts, through judicially enunciated
doctrines, impact the interpretation of tax law. Charles E Wolfe w 612 F. Supp 605 (DC Mont,
1985) aff d. 798 F.2d 1241 (9th Cir, 1986). Follow the format of the Case Brief Example on
blackboard and include: Facts Issue Decision Reasons for Decision
Solution
Facts:
Wolfe & E company's into truck trailer lease , the sole shareholder and president is
Mr.Wolfe , he is also the proprietorship of other " on the road business" under the name
of Charles .e. wolfe d/b/a Evergreen express.Wolfe did not have a seperate bank account
for the corporation , also he paid all the wages and salraies form the proprietorship
account while claiming the expenses under the corpoeration
Issue : the wolfe Corporation incurred a federal tax liability of $114,472.91 for employment
, fuel and highway use taxes and for penalties fees and interest.Wolfe paid the tax after ICC
was laid on him but he contended that Service cannot look into his personal property for
payment if the tax due.However IRS stated since corporation was alter ego of the Wolfe
Decision : It was decided that corporation was the alter ego of the Wolfe, thus justifying the
piercing of viel.
Reasons for Decision:
The wolfe did not maintain a seperate bank account , also he paid salary and wages of the
employees form the proprietorship,also wolfe was the sole shareholder and president of the
corporation,He did not consulted other directors for decision making.his personal funds
are premingled with corporations.His and corporations credit are used interchangebaly to
acquire loans, they are in the same business,sharing same address, wolfe admits to third
parties that they are one and the same, corporations income is distributed through other
means than diividends.
thus corporation and shareholder share common identity, thus it was proper for the service
to look into his personal property.