Axelrod v. Commissioner
United States Tax Court
Petitioner's sailboat had some planks shaken loose and caulking fall out during a race on August 27, 1965, in foul weather. Petitioner had an insurance policy in effect which covered any loss by storm damage to his boat, but he made no claim under this policy for damage to his boat during the race.
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Petitioner's sailboat had some planks shaken loose and caulking fall out during a race on August 27, 1965, in foul weather. Petitioner had an insurance policy in effect which covered any loss by storm damage to his boat, but he made no claim under this policy for damage to his boat during the race. Petitioner kept no records of his expenditures for such items as entertainment, convention expenses, club dues, and laundry even though he claimed business expense deductions for these items on his Federal income tax returns. Held, (1) petitioner has failed to prove that he is entitled to a…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in petitioner’s income taxes for the calendar years 1964 and 1965 in the amounts of $199.43 and $1,678.61, respectively and additions to tax under section 6653(a), I.R.C. 1954,1 for these respective years of $9.97 and $83.93.
Some of the issues raised by the pleadings have been disposed of by agreement of the parties leaving for our decision the following:(1) Whether petitioner is entitled to a deduction for a casualty loss for the year 1965 for damage to his sailboat.(2) Whether any part of petitioner’s underpayment of tax for the years 1964 and…
2Cases cited8 opinions
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Marcello v. CommissionerUnited States Tax Court · 1964
- Helvering v. OwensSupreme Court of the United States · 1939
- Matheson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1931
- Durden v. CommissionerUnited States Tax Court · 1944
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3Cited by88 opinions
- William R. And Lorna E. Hall v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- McGahen v. CommissionerUnited States Tax Court · 1981
- Eric A. Pollard v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1986
- Joseph P. Caulfield v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1994
- Henry L. And Frances O. Hills v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1982
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