Eres v. Commissioner
United States Tax Court
The petitioner owned stock in a corporation of, and located in, Yugoslavia which was deemed to have been seized, upon declaration of war between the United States and Germany in 1941, under section 127 (a) (2), Internal Revenue Code of 1939. Held, that petitioner recovered his interest in the stock in 1945, Andrew P. Solt, 19 T. C. 183, but he has failed to prove that the stock was seized or confiscated in 1945, and, therefore, loss deduction under section 23 (e) of the…
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The petitioner owned stock in a corporation of, and located in, Yugoslavia which was deemed to have been seized, upon declaration of war between the United States and Germany in 1941, under section 127 (a) (2), Internal Revenue Code of 1939. Held, that petitioner recovered his interest in the stock in 1945, Andrew P. Solt, 19 T. C. 183, but he has failed to prove that the stock was seized or confiscated in 1945, and, therefore, loss deduction under section 23 (e) of the Internal Revenue Code of 1939 is denied.
1Opinion of the Court
OPINION.
HaReon, Judge,:
Petitioner’s interest in his stock in Ris, a Yugoslav corporation, was deemed to have been destroyed or seized, pursuant to section 127 (a) (2) of the Internal Revenue Code of 1939, on December 11, 1941, when war was declared between the United States and Germany, whose forces then occupied Yugoslavia.
Petitioner contends that there was a recovery of his stock’ in 1945, brought about through his representative, Green, and that thereafter, in December of 1945, the Government of Yugoslavia, without compensation, confiscated his stock. Petitioner relies primarily upon…
2Cases cited5 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Solt v. CommissionerUnited States Tax Court · 1952
- De Reitzes-Marienwert v. CommissionerUnited States Tax Court · 1954
- Von Dattan v. CommissionerUnited States Tax Court · 1954
- Lamberton v. CommissionerUnited States Tax Court · 1945
3Cited by1 opinion
- Eres v. CommissionerUnited States Tax Court · 1954