This action was brought against the United States for a refund of income taxes paid. Plaintiff taxpayer claimed she was entitled to a deduction in 1941 for losses resulting from the embezzlement of funds by a trustee which were discovered in that year. The Commissioner of Internal Revenue disallowed the claimed deduction because the acts constituting the embezzlement had taken place during prior years. Held, judgment for defendant. Embezzlement losses are deductible in the years in which the defalcations take place, not in the years such defalcations are discovered. Alison v. United States, (D.C. Pa. 1951) 97 F. Supp. 959
In 1943 the Commissioner of Internal Revenue assessed deficiencies against respondent taxpayer in it...
Plaintiff, in 1935, purported to set up a trust of $300,000 for the benefit of her infant daughter; ...
Petitioner and one Elkins were employed by a corporation which they had organized to engage in the e...
This action was brought against the United States for a refund of income taxes paid. Plaintiff taxpa...
In the tax year in question, the taxpayer embezzled funds that came into his hands in his capacity a...
Plaintiff sold all the assets used in its business, in the middle of a fiscal year, at a price in ex...
In 1989 and 1940 the corporate taxpayer claimed as charitable deductions the value of two parcels of...
In 1932 the taxpayer sold to the X corporation, which he wholly owned and controlled, certain shares...
When a taxpayer recovers or collects an item that was deductedin an earlier year, he is ordinarily t...
The plaintiff taxpayer, as the general manager of a manufacturing corporation, received a bonus of a...
Taxpayer was accustomed to loan money to a related corporation on open accounts. The debtor consiste...
Petitioner gave shares of stock in a closely held family corporation to his wife and children. After...
Poirier & McLane Corp. v. Commissioner, 63 T.C. 570 (1975), rev\u27d, 547 F.2d 161 (2d Cir. 1976), c...
During the years 1946 to 1950 a local tax upon respondent\u27s real property was assessed at one hun...
In 1942 plaintiff employer adopted a profit-sharing plan under which a percentage of each year\u27s ...
In 1943 the Commissioner of Internal Revenue assessed deficiencies against respondent taxpayer in it...
Plaintiff, in 1935, purported to set up a trust of $300,000 for the benefit of her infant daughter; ...
Petitioner and one Elkins were employed by a corporation which they had organized to engage in the e...
This action was brought against the United States for a refund of income taxes paid. Plaintiff taxpa...
In the tax year in question, the taxpayer embezzled funds that came into his hands in his capacity a...
Plaintiff sold all the assets used in its business, in the middle of a fiscal year, at a price in ex...
In 1989 and 1940 the corporate taxpayer claimed as charitable deductions the value of two parcels of...
In 1932 the taxpayer sold to the X corporation, which he wholly owned and controlled, certain shares...
When a taxpayer recovers or collects an item that was deductedin an earlier year, he is ordinarily t...
The plaintiff taxpayer, as the general manager of a manufacturing corporation, received a bonus of a...
Taxpayer was accustomed to loan money to a related corporation on open accounts. The debtor consiste...
Petitioner gave shares of stock in a closely held family corporation to his wife and children. After...
Poirier & McLane Corp. v. Commissioner, 63 T.C. 570 (1975), rev\u27d, 547 F.2d 161 (2d Cir. 1976), c...
During the years 1946 to 1950 a local tax upon respondent\u27s real property was assessed at one hun...
In 1942 plaintiff employer adopted a profit-sharing plan under which a percentage of each year\u27s ...
In 1943 the Commissioner of Internal Revenue assessed deficiencies against respondent taxpayer in it...
Plaintiff, in 1935, purported to set up a trust of $300,000 for the benefit of her infant daughter; ...
Petitioner and one Elkins were employed by a corporation which they had organized to engage in the e...