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ALEXANDER SHOKAI, INC. v. C.I.R.S.

No. 93-70101.

34 F.3d 1480 (1994)

ALEXANDER SHOKAI, INC.; Edward Alexander; Estelle Alexander, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided September 2, 1994.

Attorney(s) appearing for the Case

Ronald K. Van Wert, Newport Beach, CA, for petitioners-appellants.

Sara S. Holderness, Tax Div., U.S. Dept. of Justice, Washington, DC, for respondent-appellee.

Before: FARRIS, O'SCANNLAIN and TROTT, Circuit Judges.

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...

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