Jones v. Commissioner

OPINION.

Van Fossan, Judge:

The question presented involves two factors— whether the pin in question was in fact stolen, and if so, its basis in the hands of the donor. It is respondent’s contention with regard to the first factor that the facts adduced on the record do not offer a basis for drawing a logical inference that the pin was lost by theft. To support such position, respondent relies heavily upon our opinion in Mary Frances Allen, 16 T. C. 163.

The case so relied upon is clearly distinguishable from the one before us. There, the taxpayer lost a brooch while visiting the Metropolitan…