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JOHNSON v. UNITED STATES

No. 81-4621.

698 F.2d 372 (1982)

Charles JOHNSON, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided December 27, 1982.

Rehearing and Rehearing Denied February 16, 1983.

Attorney(s) appearing for the Case

Robert L. Dunnett, Los Gatos, Cal., for plaintiff-appellant.

Kristina E. Harrigan, Washington, D.C., for defendant-appellee.

Before MERRILL, FLETCHER and BOOCHEVER, Circuit Judges.

Rehearing and Rehearing En Banc Denied February 16, 1983.

MERRILL, Circuit Judge:

Appellant Johnson seeks refund of federal income taxes for the year 1978 in the sum of $52,606, and appeals from the district court's grant of summary judgment for the government.

I.

Appellant is a professional basketball player. In 1974 he signed a contract with a Panamanian Corporation, Presentaciones Musicales S.A. ("PMSA"), conveying to it the exclusive...

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