Louisa B. Gunther Farcasanu v. Commissioner of Internal Revenue

In this appeal we are urged to reverse a decision of the Tax Court holding that appellant was properly denied a deduction which she claimed on her income tax return for calendar year 1959 under section 165(c) (3) of the Internal Revenue Code of 1954 1 for losses allegedly incurred as a result of theft of personal property. For reasons to be stated more fully below, we conclude that the decision of the Tax Court is correct and must be affirmed.

Because appellant’s attempts to recover some compensation for her property extend over several decades and arise out of unusual circumstances, a…