Estate of Bryan v. Commissioner
United States Tax Court
An attorney embezzled funds from decedent's estate. Partial reimbursement was received from the Client's Security Trust Fund, an organization established pursuant to Maryland law to reimburse losses caused by defalcations of members of the bar. Held, pursuant to sec. 2054, I.R.C. 1954, petitioner must reduce the amount of theft loss in an amount equal to the reimbursement received.
1Opinion of the Court
Estate of Louise D. Bryan, Deceased, Corinne Bryan Mitsak, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Bryan v. Commissioner
Docket No. 2505-78
United States Tax Court
74 T.C. 725; 1980 U.S. Tax Ct. LEXIS 100;
July 21, 1980, Filed
Decision will be entered for the respondent.
An attorney embezzled funds from decedent's estate. Partial reimbursement was received from the Client's Security Trust Fund, an organization established pursuant to Maryland law to reimburse losses caused by defalcations of members of the bar. Held, pursuant to sec. 2054, I.R.C.…
2Cases cited4 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Durden v. CommissionerUnited States Tax Court · 1944
- Shanahan v. CommissionerUnited States Tax Court · 1974
- Estate of Bryan v. CommissionerUnited States Tax Court · 1980