Legal Opinion

Alexander Shokai, Inc. Edward Alexander Estelle Alexander v. Commissioner of Internal Revenue Service

Court of Appeals for the Ninth Circuit

Decided September 2, 1994No. 93-70101PublishedCited by 30 opinions

1Opinion of the Court

FARRIS, Circuit Judge:

Taxpayers Alexander Shokai, Inc., Edward Alexander and Estelle Alexander appeal the decision of the tax court denying them a redetermination of approximately $2 million in back taxes and penalties asserted by the Commissioner. The tax court had jurisdiction under 26 U.S.C. §§ 6213, 6214 and 7442. We have jurisdiction pursuant to 26 U.S.C. § 7482, and we affirm.

I. Facts

In the 1960’s, Gosen Co., Ltd., a Japanese manufacturer of tennis strings, granted Edward Alexander the right to sell its string as a wholesaler in the United States. The business began in the home of Mr.…

2Cases cited23 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  3. Robert W. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
  4. Healy v. CommissionerSupreme Court of the United States · 1953
  5. Joseph Edelson and Harriet Edelson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987

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3Cited by30 opinions

  1. William Ludwig v. Michael AstrueCourt of Appeals for the Ninth Circuit · 2012
  2. United States v. Emerson SeschillieCourt of Appeals for the Ninth Circuit · 2002
  3. United States v. Randolph GeorgeCourt of Appeals for the Ninth Circuit · 2005
  4. In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016
  5. Kelley v. CommissionerCourt of Appeals for the Ninth Circuit · 1995

25 more not listed; retrieve them via the Exa API.

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