Ramsay Scarlett & Co. v. Commissioner
United States Tax Court
In September 1965, petitioners Ramsay Scarlett and Baltimore Stevedoring discovered that their bookkeeper had embezzled approximately $ 1.5 million of corporate funds. The majority of the embezzlements were accomplished by the use of four different types of corporate checks. As to each of three of such types, some checks were drawn and paid prior to the enactment of the Uniform Commercial Code in Maryland, and some afterwards.
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In September 1965, petitioners Ramsay Scarlett and Baltimore Stevedoring discovered that their bookkeeper had embezzled approximately $ 1.5 million of corporate funds. The majority of the embezzlements were accomplished by the use of four different types of corporate checks. As to each of three of such types, some checks were drawn and paid prior to the enactment of the Uniform Commercial Code in Maryland, and some afterwards. Insurance provided only $ 50,000 of recovery for petitioners in 1965. In 1969, petitioners received $ 475,000 as a settlement from the bank at which all the checks…
1Opinion of the Court
FORRESTER, Judge:
In these consolidated cases respondent has determined the following deficiencies in petitioners’ Federal income taxes:
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Because of concessions, the only issue remaining for our decision is whether the petitioners are entitled under section 165(e)1 to claim deductions in 1965 for theft losses resulting from embezzlements of corporate funds.
BINDINGS OB BACT
Some of the facts have been stipulated and are so found.
Petitioner Bamsay Scarlett & Co., Inc. (Bamsay), is a Maryland corporation which had its principal office in Baltimore, Md., at the time the petition herein…
2Cases cited48 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Boehm v. CommissionerSupreme Court of the United States · 1945
- Lewellyn v. Electric Reduction Co.Supreme Court of the United States · 1927
- Stone & Webster Engineering Corp. v. First National Bank & Trust Co.Massachusetts Supreme Judicial Court · 1962
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3Cited by97 opinions
- 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
- Hudock v. CommissionerUnited States Tax Court · 1975
- Edwin Christman Dawn and June Estelle Dawn v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Jeppsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1997
- Zinn v. United StatesDistrict Court, N.D. Ohio · 2012
92 more not listed; retrieve them via the Exa API.