Legal Opinion
William P. Cheng v. Commissioner Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided July 5, 1991No. 90-70312PublishedCited by 4 opinions
1Opinion of the Court
ALARCON, Circuit Judge:
William P. Cheng deducted $30,000 from his income in 1977 and $60,000 in 1978 based on royalty payments he made in those years on diamond mining investments. The Commissioner of the Internal Revenue Service disallowed the deductions, proposing a deficiency in taxes paid for those years. Cheng petitioned the Tax Court for a review of the ruling.
Cheng appeals from the Tax Court’s order granting summary judgment in favor of the Commissioner. He argues that the payments were deductible as minimum annual royalty payments under Treas.Reg. 1.612-3(b)(3). This case also…
2Cases cited5 opinions
- Singleton v. WulffSupreme Court of the United States · 1976
- William P. Cheng v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
- Michael-Regan Co. v. LindellCourt of Appeals for the Ninth Circuit · 1975
- Jimmie J. And Bonnie M. Ward v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1986
- Norman J. Fredkin and Annie G. Fredkin v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1989
3Cited by4 opinions
- Larry D. Delpit Dorothy D. Delpit v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1994
- John W. Roberts, Cheryl W. Roberts v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1999
- United States v. Sternberg (In Re Sternberg)District Court, S.D. Florida · 1998
- Idaho First National Bank Moore Financial Group, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1993