Legal Opinion

Thornton v. Commissioner

United States Tax Court

Decided October 6, 1966No. Docket No. 3809-64PublishedCited by 19 opinions

Held, that portion of the decline in market value of a residence which is attributable to a fear of recurring floods and which is not caused by actual physical damage to the residence is not deductible as a casualty loss under sec. 165, I.R.C. 1954.1Unless otherwise indicated, all statutory references are to the Internal Revenue Code of 1954

1Opinion of the Court

Hoyt, Judge:

This case involves the determination by the Commissioner of a deficiency in the income tax of the petitioners in the amount of $716.19 for the calendar year 1961. The Commissioner made the following adjustments in recomputing the petitioners’ tax for the year in question:(a) The disallowance of $4,513.75 of a claimed casualty loss deduction totaling $5,083.75.(b) The disallowance of a deduction for club dues in the amount of $30.(c) The allowance of an unclaimed interest deduction in the amount of $35.27.(d) The allowance of an unclaimed tax deduction in the amount of $5.94.

Petitio…

2Cases cited6 opinions

  1. The Citizens Bank of Weston v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
  2. Austin Clapp, Gloria Clapp, Stuart P. Clapp, and Virginia M. Clapp v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
  3. Citizens Bank of Weston v. CommissionerUnited States Tax Court · 1957
  4. Peterson v. CommissionerUnited States Tax Court · 1958
  5. J. G. Boswell Co. v. CommissionerUnited States Tax Court · 1960

1 more not listed; retrieve them via the Exa API.

3Cited by19 opinions

  1. Squirt Co. v. CommissionerUnited States Tax Court · 1969
  2. Pulvers v. CommissionerUnited States Tax Court · 1967
  3. Kamanski v. CommissionerUnited States Tax Court · 1970
  4. Black v. CommissionerUnited States Tax Court · 1977
  5. Ford v. CommissionerUnited States Tax Court · 1974

14 more not listed; retrieve them via the Exa API.

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