Legal Opinion

Roy C. Wilkin v. United States

Court of Appeals for the Ninth Circuit

Decided February 9, 1987No. 85-6389PublishedCited by 5 opinions

1Opinion of the Court

WILLIAM D. BROWNING, District Judge:

Wilkin appeals from the dismissal of his complaint and the granting of the United States’ motion for summary judgment on its counterclaim for back taxes and penalties. Wilkin is an American citizen who resided and practiced dentistry in Canada from 1962 until 1973. During the period he was residing in Canada, Wilkin invested in a number of Canadian securities, bought on the margin with only a 10 percent cash investment. 1 Wilkin maintained his United States citizenship and filed annual tax returns with the U.S. Internal Revenue Service while he was residing…

2Cases cited8 opinions

  1. Singleton v. WulffSupreme Court of the United States · 1976
  2. Perrin v. United StatesSupreme Court of the United States · 1979
  3. Crane v. CommissionerSupreme Court of the United States · 1947
  4. Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
  5. Eve C.W. Wallin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984

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3Cited by5 opinions

  1. Chapman Glen Ltd. v. CommissionerUnited States Tax Court · 2013
  2. Raymond Syufy Marcia Syufy, Plaintiffs-Counterclaim v. United States of America, Defendant-Counterclaimant-AppellantCourt of Appeals for the Ninth Circuit · 1987
  3. Chapman Glen Limited v. CommissionerUnited States Tax Court · 2013
  4. John Bagent v. Richard PierceCourt of Appeals for the Ninth Circuit · 2011
  5. Tarpey v. United StatesDistrict Court, D. Montana · 2021

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