Solt v. Commissioner
United States Tax Court
In 1934 petitioner inherited a one-sixth interest in a farm in Hungary. He sustained a war loss with respect to that interest in 1942 when war was declared between the United States and Hungary. A formal armistice was signed on January 20, 1945. In February and early March 1945, petitioner's brother, acting on behalf of himself and the other co-owners of the farm, regained possession of the property, and appointed someone as their representative to manage the farm.
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In 1934 petitioner inherited a one-sixth interest in a farm in Hungary. He sustained a war loss with respect to that interest in 1942 when war was declared between the United States and Hungary. A formal armistice was signed on January 20, 1945. In February and early March 1945, petitioner's brother, acting on behalf of himself and the other co-owners of the farm, regained possession of the property, and appointed someone as their representative to manage the farm. Shortly thereafter, on March 15, 1945, the farm was confiscated by the Provisional National Government of Hungary, as part of a…
1Opinion of the Court
OPINION.
Raum, Judge:
Petitioner’s claim to the deduction in controversy rests upon the following chain of reasoning: (1) that his one-sixth interest in the farm was deemed to have been destroyed or seized, pursuant to section 127 (a) (2)1 of the Internal Eevenue Code, on June 5, 1942, when the United States declared war on Hungary; (2) that he recovered that interest on January 20, 1945, or, alternatively, on February 22, 1945, within the meaning of section 127 (c);2 and (3) that he again suffered a loss of that interest on March 15,1945, as a result of confiscation by the Provisional National…
2Cases cited7 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Helvering v. TaylorSupreme Court of the United States · 1935
- Abraham v. CommissionerUnited States Tax Court · 1947
- Adler v. CommissionerUnited States Tax Court · 1947
- Heckett v. CommissionerUnited States Tax Court · 1947
2 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Feinstein v. CommissionerUnited States Tax Court · 1955
- Camp Wolters Enterprises, Inc. v. CommissionerUnited States Tax Court · 1954
- Popa v. CommissionerUnited States Tax Court · 1979
- Wyman v. United StatesUnited States Court of Claims · 1958
- Brown v. CommissionerUnited States Tax Court · 1955
22 more not listed; retrieve them via the Exa API.