Legal Opinion
United States v. Good Samaritan Church Jerome F. Przybyla and Priscilla Przybyla
Court of Appeals for the Ninth Circuit
Decided July 7, 1994No. 93-35017PublishedCited by 24 opinions
1Opinion of the Court
KLEINFELD, Circuit Judge:
We dismiss this appeal because the appellants won the case below. They lost on the issue which they want us to review, but the decision on that issue has no effect on them.
The Przybylas transferred property to the Good Samaritan Church. A year later, the IRS assessed a tax deficiency against them. The IRS seized the church property on the ground that Good Samaritan Church was the nominee or alter ego of the Przybylas. The IRS bid the property in an auction, and brought this action to quiet title to the church property.
On cross-motions for summary judgment, the…
2Cases cited8 opinions
- Montana v. United StatesSupreme Court of the United States · 1979
- Deposit Guaranty National Bank v. RoperSupreme Court of the United States · 1980
- Alltrade, Inc. v. Uniweld Products, Inc.Court of Appeals for the Ninth Circuit · 1991
- Electrical Fittings Corp. v. ThomasSupreme Court of the United States · 1939
- Towe Antique Ford Foundation, a Nonprofit Montana Corporation v. Internal Revenue Service Department of Treasury United States of AmericaCourt of Appeals for the Ninth Circuit · 1993
3 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Gabriel Ruvalcaba v. City of Los Angeles Daryl Gates, Martin Coon, ( 21604) in Both Their Personal and Official CapacitiesCourt of Appeals for the Ninth Circuit · 1999
- Pension Trust Fund for Operating Engineers, Plaintiff-Appellant-Cross-Appellee v. Federal Insurance Company, Defendant-Appellee-Cross-AppellantCourt of Appeals for the Ninth Circuit · 2002
- United States v. Clarke Dexter WeemsCourt of Appeals for the Ninth Circuit · 1995
- Dixon v. Wallowa CountyCourt of Appeals for the Ninth Circuit · 2003
- Equal Employment Opportunity Commission v. The Chicago ClubCourt of Appeals for the Seventh Circuit · 1996
19 more not listed; retrieve them via the Exa API.