Legal Opinion
Kudo v. Commissioner
Court of Appeals for the Ninth Circuit
Decided April 6, 2001No. Nos. 99-70947, 0971-3PublishedCited by 5 opinions
1Opinion of the Court
MEMORANDUM *
We affirm the Tax Court’s decision upholding deficiencies and penalties. As the parties are familiar with the factual and procedural history of this case, we do not recount them here.
1. Standard of Review
We review the tax court’s conclusions of law de novo and its factual findings for clear error. Baizer v. Comm’r, 204 F.3d 1231, 1233-34 (9th Cir.2000). We review a tax court’s affirmance of a penalty for clear error. Collins v. Comm’r, 857 F.2d 1383, 1386 (9th Cir.1988).
2. Jurisdiction over the appeal of Toraya Corporation
A tax court decision is “reviewable only if there is a…
2Cases cited7 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Clayton v. CommissionerUnited States Tax Court · 1994
- Cathy Miller Hardy v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
- Pessin v. CommissionerUnited States Tax Court · 1972
- David G. Collins Pamela Collins Bernie Gates Maureen Gates Anne Hamsley and David Dister v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
2 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Thompson v. Comm'rUnited States Tax Court · 2011
- MacGregor v. Comm'rUnited States Tax Court · 2010
- Brooks v. Comm'rUnited States Tax Court · 2012
- Martell v. Comm'rUnited States Tax Court · 2013
- YANG-WU v. COMMISSIONERUnited States Tax Court · 2002