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Van Dorn Co. v. Future Chemical and Oil Corp., 753 F.2d 565 (7th Cir. 1985) held that a corporate entity will be disregarded and the veil of limited liability pierced when two requirements are met: First, there must be such unity of interest and ownership that the separate personalities of the corporation and the individual [or other corporation] no longer exist; and second, circumstances must be such that adherence to the fiction of separate corporate existence would sanction a fraud or promote injustice. 753 F.2d at 569-70 (quoting Macaluso v. Jenkins, 95 Ill. App. 3d 461, 420 N.E.2d 251, 255, 50 Ill. Dec. 934 (1981)) (other citations omitted). See also Main Bank of Chicago v. Baker, 86 Ill. 2d 188, 205, 427 N.E.2d 94, 101, 56 Ill. Dec. 14 (1981) (Illinois Supreme Court stating the test in essentially the same terms); Pederson v. Paragon Pool Enterprises, 214 Ill. App. 3d 815, 1991 Ill. App. LEXIS 880, at *7 158 Ill. Dec. 371, 574 N.E.2d 165 (1st Dist. 1991) (recent veil-piercing case applying essentially the same test).


As for determining whether a corporation is so controlled by another to justify disregarding their separate identities, Van ...

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