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CHENG v. C.I.R.

No. 90-70312.

938 F.2d 141 (1991)

William P. CHENG, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided July 5, 1991.

Attorney(s) appearing for the Case

Eugene D. Silverman, Yaakov G. Vanek, Michael C. Cohen, DeCastro, West, Chodorow & Burns, Los Angeles, Cal., for petitioner-appellant.

Gary R. Allen and Steven Parks, Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before GOODWIN, PREGERSON and ALARCON, Circuit Judges.

ALARCON, Circuit Judge:

William P. Cheng deducted $30,000 from his income in 1977 and $60,000 in 1978 based on royalty payments he made in those years on diamond mining investments. The Commissioner of the Internal Revenue Service disallowed the deductions, proposing a deficiency in taxes paid for those years. Cheng petitioned the Tax Court for a review of the ruling.

Cheng appeals from the Tax Court's order granting summary judgment in favor of the Commissioner...

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