Legal Opinion
William P. Cheng v. Commissioner Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided June 27, 1989No. 87-7447PublishedCited by 76 opinions
1Opinion of the Court
WIGGINS, Circuit Judge:
William P. Cheng appeals from the Tax Court’s grant of partial summary judgment in favor of the Commissioner of the Internal Revenue Service (Commissioner) upholding the Commissioner’s determination that Cheng’s minimum royalty payments of $20,000 in 1977 and $60,000 in 1978 for unmined diamonds were not deductible under Treas.Reg. § 1.612-3(b)(3) (as amended in 1977). We conclude that we lack jurisdiction for want of an appealable final order and dismiss the appeal.
I
In 1977, Cheng entered into a five-year mining sublease with Imperial Finance, N.V. (Imperial). Under…
2Cases cited17 opinions
- Eisen v. Carlisle & JacquelinSupreme Court of the United States · 1974
- Coopers & Lybrand v. LivesaySupreme Court of the United States · 1978
- Catlin v. United StatesSupreme Court of the United States · 1945
- Firestone Tire & Rubber Co. v. RisjordSupreme Court of the United States · 1981
- Flanagan v. United StatesSupreme Court of the United States · 1984
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3Cited by76 opinions
- Watkins v. City of OaklandCourt of Appeals for the Ninth Circuit · 1998
- Catherine Evon v. Law Offices of Sidney MickellCourt of Appeals for the Ninth Circuit · 2012
- United States v. Lucio MoralesCourt of Appeals for the Ninth Circuit · 1990
- Robin James, a Married Person in Her Separate Capacity v. Price Stern Sloan, Inc., a Delaware Corporation Penguin Putnam, Inc., a Delaware CorporationCourt of Appeals for the Ninth Circuit · 2002
- Allen v. City of Los AngelesCourt of Appeals for the Ninth Circuit · 1995
71 more not listed; retrieve them via the Exa API.