Legal Opinion
Johnson v. United States
United States Court of Federal Claims
Decided December 21, 2006No. Nos. 01-428T, 03-2803T, 05-1265TPublishedCited by 5 opinions
1Opinion of the Court
*361OPINION
FIRESTONE, Judge.
This case comes before the court on a motion by defendant, the United States (“government”), for partial summary judgment pursuant to Rule 56 of the Rules of the United States Court of Federal Claims (“RCFC”). The government seeks summary judgment on the proper interpretation of the theft loss provision of the Internal Revenue Code (“IRC”) § 165(e). At issue is the appropriate timing of a theft loss deduction. The plaintiffs, Aben E. Johnson and Joan G. Johnson (“plaintiffs” or “Johnsons”), had money stolen from them in 1997 and claimed a theft loss deduction in 1998…
2Cases cited11 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Ramsay Scarlett & Co. v. CommissionerUnited States Tax Court · 1974
- Ramsay Scarlett and Company, Inc. v. Commissioner of Internal Revenue, Baltimore Stevedoring Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1975
- Parmelee Transportation Company v. The United StatesUnited States Court of Claims · 1965
- Elizabeth A. Reese v. United StatesCourt of Appeals for the Federal Circuit · 1994
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3Cited by5 opinions
- Adkins v. United StatesUnited States Court of Federal Claims · 2016
- Adkins v. United StatesCourt of Appeals for the Federal Circuit · 2017
- Johnson v. United StatesUnited States Court of Federal Claims · 2008
- Johnson v. United StatesUnited States Court of Federal Claims · 2007
- Adkins v. United StatesUnited States Court of Federal Claims · 2016