Legal Opinion

Axelrod v. Commissioner

United States Tax Court

Decided May 10, 1971No. Docket No. 4063-69Published

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

David Axelrod, Petitioner v. Commissioner of Internal Revenue, Respondent

Axelrod v. Commissioner

Docket No. 4063-69

United States Tax Court

56 T.C. 248; 1971 U.S. Tax Ct. LEXIS 134;

May 10, 1971, Filed

Decision will be entered under Rule 50.

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…

Also in this document: Concurrence · Fay; Concurrence · Simpson; Concurrence · Quealy.

2Cases cited14 opinions

  1. 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
  2. Marcello v. CommissionerUnited States Tax Court · 1964
  3. Helvering v. OwensSupreme Court of the United States · 1939
  4. Axelrod v. CommissionerUnited States Tax Court · 1971
  5. Matheson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1931

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