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BOB WONDRIES MOTORS, INC. v. C.I.R.

Nos. 00-70530, 00-70538, 00-70541, 00-70553, 00-70555, 00-70560 and 00-70561.

268 F.3d 1156 (2001)

BOB WONDRIES MOTORS, INC., dba Wondries Ford, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Toyota Town, Inc., a California corporation, Petitioner-Appellant, v. Commissioner of Internal Revenue, Respondent-Appellee. Wondries Nissan, Inc., Petitioner-Appellant, v. Commissioner of Internal Revenue, Respondent-Appellee. Country Nissan, a California corporation, Petitioner-Appellant, v. Commissioner of Internal Revenue, Respondent-Appellee. Quality Motor Cars of Stockton, a California corporation, Petitioner-Appellant, v. Commissioner of Internal Revenue, Respondent-Appellee. Bob Wondries Associates, Inc., d.b.a. Wondries Toyota, Petitioner, v. Commissioner of Internal Revenue, Respondent. Robert S. Zamora and Christina Zamora, Petitioners, v. Commissioner of Internal Revenue, Respondent.

United States Court of Appeals, Ninth Circuit.

Filed October 23, 2001.

Attorney(s) appearing for the Case

Avram Salkin (argued) and Michael R. Stein, Hochman, Salkin, Rettig, Toscher & Perez, Beverly Hills, California, for the petitioners-appellants.

Frank P. Cihlar (argued) and Joan I. Oppenheimer, United States Department of Justice, Tax Division, Washington, D. C., for the respondent-appellee.

Before: BRUNETTI, RYMER, and WARDLAW, Circuit Judges.

Argued and Submitted October 11, 2001 — Pasadena, California.

OPINION

RYMER, Circuit Judge:

Bob Wondries Motors, Inc., Toyota Town, Inc., Wondries Nissan, Inc., Country Nissan, Quality Motor Cars of Stockton, Bob Wondries Associates, Inc., Robert S. Zamora and Christina Zamora (taxpayers) appeal the Tax Court's decision upholding tax deficiencies assessed by the Commissioner of the Internal Revenue Service.1 Taxpayers...

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