Legal Opinion
James J. Parker and Rosemarie Parker v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided July 22, 1987No. 86-7045Published
1Opinion of the Court
BRUNETTI, Circuit Judge:
FACTS
The individual taxpayer designed and built dollar slot machines. He leased some of them to the Lady Luck casino and received fixed periodic payments. He also placed some of the machines in the Golden Gate casino and signed a “participation agreement” under which he received 40% of the net profits produced by his machines. Under both agreements, the taxpayer was required to service, maintain, modify, and update the machines.
The taxpayer designed all of the component parts. He built some of the components and hired a machine shop to fabricate others.
On his 1977 and…
2Cases cited8 opinions
- United States v. Winston Bryant McConneyCourt of Appeals for the Ninth Circuit · 1984
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- David C. Enrici Marianne Enrici Lawrence H. Easterling Phyllis Easterling v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1987
- Cook v. United StatesUnited States Court of Claims · 1979
- The United States v. L.J. And Marjorie Van DykeCourt of Appeals for the Federal Circuit · 1982
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