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WILKIN v. UNITED STATES

No. 85-6389.

809 F.2d 1400 (1987)

Roy C. WILKIN, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided February 9, 1987.

Attorney(s) appearing for the Case

Bruce Hochman, Beverly Hills, Cal., for plaintiff-appellant.

Robert Bernstein and Murray S. Horwitz, Washington, D.C., for defendant-appellee.

Before SNEED and SCHROEDER, Circuit Judges, and WILLIAM D. BROWNING, District Judge.

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.

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