Legal Opinion

Daniel A. Robida v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided May 23, 1972No. 26910PublishedCited by 23 opinions

1Opinion of the Court

DUNIWAY, Circuit Judge:

The Commissioner of Internal Revenue determined substantial deficiencies in Robida’s federal income tax for the years 1956-61. The tax court held that the income in question was exempt under section 911 of the Internal Revenue Code of 1954. 1 The Commissioner appeals. We affirm.

BACKGROUND

Robida is an American citizen who lived abroad during the years in question and who derived his income from slot machine pay-offs in various United States military service clubs. To eliminate the element of chance and thereby guarantee his “winnings,” Robida would manipulate the slot…

2Cases cited1 opinion

  1. Daniel A. Robida v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1967

3Cited by23 opinions

  1. Sally Conforte v. Commissioner of Internal Revenue, Joseph Conforte v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
  2. Cook v. United StatesUnited States Court of Claims · 1979
  3. Tobey v. Comm'rUnited States Tax Court · 1973
  4. The United States v. L.J. And Marjorie Van DykeCourt of Appeals for the Federal Circuit · 1982
  5. Vogt v. United StatesUnited States Court of Claims · 1976

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