Ternovsky v. Commissioner
United States Tax Court
Petitioners claimed the theft of their stamp collection as a casualty loss. Respondent disallowed the deduction. Held, the 280,000 Hungarian forints petitioners paid in 1949 for the stamp collection are to be converted into U.S. dollars at the black market rate. Held, further, petitioners' insurance recovery was in excess of their basis; therefore, they did not incur a deductible theft loss.
1Opinion of the Court
Irwin, Judge:
Respondent determined deficiencies in petitioners’ income tax as follows:
Year Deficiency
1966_ $1,177.00
1967_ 770.26
1969_ 1,695.87
The issues presented for our determination are the amount paid in Hungary in 1949 for a stamp collection and the conversion of that amount into United States dollars. The claimed deduction which respondent disallowed relates to a casualty loss resulting from a theft of the stamp collection from petitioners’ house.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and the exhibits attached thereto are incorporated herein by…
2Cases cited5 opinions
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Durovic v. CommissionerUnited States Tax Court · 1970
- Marko Durovic v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
- Ferdinand Cinelli and Sarah M. Cinelli v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1974
- Durovic v. CommissionerUnited States Tax Court · 1975
3Cited by14 opinions
- Reed v. CommissionerUnited States Tax Court · 1986
- Bodine v. CommissionerUnited States Tax Court · 1978
- Ruben v. CommissionerUnited States Tax Court · 1987
- Andrew G. Shank v. CommissionerUnited States Tax Court · 2018
- Bigelow v. CommissionerUnited States Tax Court · 1979
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