U.S. v. GOOD SAMARITAN CHURCH

No. 93-35017.

29 F.3d 487 (1994)

UNITED STATES of America, Plaintiff-Appellee, v. GOOD SAMARITAN CHURCH; Jerome F. Przybyla and Priscilla Przybyla, Defendants-Appellants.

United States Court of Appeals, Ninth Circuit.

Decided July 7, 1994.


Attorney(s) appearing for the Case

Jeffrey A. Dickstein, Tulsa, OK, for defendants-appellants.

Michael L. Paup, Acting Asst. Atty. Gen., Washington, DC, for plaintiff-appellee.

Before: POOLE, BRUNETTI and KLEINFELD, Circuit Judges.


KLEINFELD, Circuit Judge:

We dismiss this appeal because the appellants won the case below. They lost on the issue which they want us to review, but the decision on that issue has no effect on them.

The Przybylas transferred property to the Good Samaritan Church. A year later, the IRS assessed a tax deficiency against them. The IRS seized the church property on the ground that Good Samaritan Church was the nominee or alter ego of the Przybylas. The IRS bid...

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