Houdry v. Commissioner
United States Tax Court
Loss of French property located in German-controlled territory when United States entered war and previously expropriated by Vichy Government, also in 1941, held deductible in that year by petitioner, then a resident alien of the United States, either pursuant to I. R. C., section 127 (war losses), or United States v. White Dental Mfg. Co., 274 U.S. 398.
1Opinion of the Court
OPINION.
OppeR, Judge:
Only if the provisions of section 127, Internal Revenue Code, dealing with “war losses,”1 were intended to be exclusive can respondent’s disallowance of the present claim be sustained, even on his own contention. Petitioner lost his French citizenship in May 1941, as is stipulated, and his title to the French property in question a few weeks later, according to respondent’s view of the facts. Based upon this hypothesis, and his interpretative regulation,2 the claim has been disallowed because petitioner did not own the property when the United States entered the war in…
2Cases cited3 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Ford v. Comm'rUnited States Tax Court · 1946
- M. C. Parrish & Co. v. CommissionerUnited States Tax Court · 1944
3Cited by19 opinions
- Edward T. And Isabel J. Lysek v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
- Adler v. CommissionerUnited States Tax Court · 1947
- Andriesse v. CommissionerUnited States Tax Court · 1949
- Ribas v. CommissionerUnited States Tax Court · 1970
- Wyman v. United StatesUnited States Court of Claims · 1958
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