Colish v. Commissioner
United States Tax Court
Held, no claim for reimbursement with respect to which there was a reasonable prospect of recovery existed at the time petitioners' property was nationalized by Communist Czechoslovakia, even though petitioner then knew of Czechoslovakian assets in this country, consequently he may not deduct his loss in a later year when his claim was partially satisfied out of the Czecholovakian Claims Fund.
1Opinion of the Court
FoRkesteR, Judge:
The respondent determined a deficiency in petitioners’ income tax for the year 1962 in the amount of $1,135.96. The only issue is whether petitioners sustained a deductible loss in 1962 when a final payment was received from the Foreign Claims Settlement Commission as compensation for Czechoslovakian property confiscated in an earlier year.
FINDINGS OF FACT
Some of the facts are stipulated and are so found.
The petitioners, Harry J. and Ruth B. Colish, are individuals, husband and wife, who at all relevant times have resided in New York City. They filed a joint return for the…
2Cases cited5 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Elek v. CommissionerUnited States Tax Court · 1958
- Wyman v. United StatesUnited States Court of Claims · 1958
- Paul H. Schweitzer and Friedel Schweitzer v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1967
- Remington Typewriter Co. v. CommissionerUnited States Board of Tax Appeals · 1926
3Cited by15 opinions
- Reading & Bates Corp. v. United StatesUnited States Court of Federal Claims · 1998
- Halliburton Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991
- Halliburton Co. v. CommissionerUnited States Tax Court · 1989
- Estate of Frank Fuchs, Deceased, Edith Fuchs, and Edith Fuchs, Surviving Wife Individually v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Cesar E. Alvarez Et Ux. v. United StatesCourt of Appeals for the Fifth Circuit · 1970
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