Legal Opinion
Suzy's Zoo (R) v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided November 21, 2001No. 00-70461PublishedCited by 41 opinions
1Opinion of the Court
SNEED, Circuit Judge:
Suzy’s Zoo appeals from the U.S. Tax Court, challenging a deficiency finding for its tax year ending June 30, 1994. The Tax Court held that Suzy’s Zoo exercised such degree of control over the manufacturing of its products by third party contractors that it was a “producer” under Internal Revenue Code (“I.R.C.”) § 263A, 1 and that it did not qualify for the small reseller exception of I.R.C. § 263A(b)(2)(B) and could not deduct its production costs. The Tax Court also held that the “year of change” under I.R.C. § 481(a) was the first taxable year (1994) in which Suzy’s…
2Cases cited16 opinions
- Commissioner v. BilderSupreme Court of the United States · 1962
- Graff Chevrolet Company v. Ellis Campbell, Jr., District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1965
- James L. Redlark Cheryl L. Redlark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998
- Carbon Steel Co. v. LewellynSupreme Court of the United States · 1920
- Charles Peckat Mfg. Co. v. JareckiCourt of Appeals for the Seventh Circuit · 1952
11 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- Commissioner of Internal Revenue v. Gwendolyn A. Ewing, Gwendolyn A. Ewing v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
- Adkison v. CommissionerCourt of Appeals for the Ninth Circuit · 2010
- Hoyle v. Ada CountyCourt of Appeals for the Ninth Circuit · 2007
- River City Ranches # 1 Ltd. v. Commissioner Of Internal RevenueCourt of Appeals for the Ninth Circuit · 2005
- United States v. Edward Rosenthal, United States of America v. Edward RosenthalCourt of Appeals for the Ninth Circuit · 2006
36 more not listed; retrieve them via the Exa API.