Norton v. Commissioner
United States Tax Court
Petitioner entered into an agreement with a licensed California contractor for the construction of a swimming pool on her property, payment to be made as the work progressed.
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Petitioner entered into an agreement with a licensed California contractor for the construction of a swimming pool on her property, payment to be made as the work progressed. After petitioner had paid approximately 85 percent of the agreed price to the contractor upon his representations that the work was being done in accordance with the contract and that subcontractors and materialmen were being paid, the contractor left the work incomplete, and 4 days thereafter was adjudicated a bankrupt. The work was not, in fact, done in accordance with the specifications in the contract and some of the…
1Opinion of the Court
OPINION
Scott, Judge:
Respondent determined a deficiency in petitioner’s income tax for tlie calendar year 1959 in the amount of $10,595.53. The issue for decision is whether the amount of $13,631.05 which was the total cost to petitioner of the failure of a contractor to properly complete a swimming pool on petitioner’s property or any portion of this amount is deductible by petitioner as a theft loss.
All of the facts have been stipulated and are found accordingly.
Petitioner, an individual residing in Piedmont, Calif., filed her Federal income tax return for the calendar year 1959 with the…
2Cases cited8 opinions
- People v. AshleyCalifornia Supreme Court · 1954
- Monteleone v. CommissionerUnited States Tax Court · 1960
- People v. HolderCalifornia Court of Appeal · 1921
- People v. JacksonCalifornia Court of Appeal · 1937
- People v. SchmidtCalifornia Court of Appeal · 1956
3 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Nichols v. CommissionerUnited States Tax Court · 1965
- West v. CommissionerUnited States Tax Court · 1987
- Bellis v. CommissionerUnited States Tax Court · 1973
- Evelyn Nell Norton v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- Skolnik v. CommissionerUnited States Tax Court · 1971
21 more not listed; retrieve them via the Exa API.