Lieberfarb v. Commissioner
United States Tax Court
In 1967 petitioner paid $ 8,000 to settle a damage suit arising from an automobile accident which occurred in 1961. He alleges he was entitled to indemnification under a policy written by an insurance company which was dissolved and placed in liquidation in 1965. Claims to participate in the liquidation proceeds were required to be filed on or before Apr. 15, 1966, and petitioner did not file his claim until 1971. He recovered nothing on the claim, and he alleges he is…
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In 1967 petitioner paid $ 8,000 to settle a damage suit arising from an automobile accident which occurred in 1961. He alleges he was entitled to indemnification under a policy written by an insurance company which was dissolved and placed in liquidation in 1965. Claims to participate in the liquidation proceeds were required to be filed on or before Apr. 15, 1966, and petitioner did not file his claim until 1971. He recovered nothing on the claim, and he alleges he is entitled to a nonbusiness bad debt deduction in 1967 under sec. 166(d), I.R.C. 1954, for the amount paid to settle the suit.…
1Opinion of the Court
OPINION
FeatheRSTon, Judge:
Respondent determined a deficiency in petitioner’s Federal income tax for 1967 in the amount of $4,125.67. The issue for decision is whether petitioner is entitled to deduct as a non-business bad debt loss, under section 166,1 an amount which he paid to settle a damage claim arising from an automobile accident and for which he alleges he was entitled to, but did not receive, reimbursement from a defunct insurance company.
All the facts are stipulated.
Petitioner filed his 1967 Federal income tax return with the district director of internal revenue in Chicago, Ill.,…
2Cases cited14 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Dallmeyer v. CommissionerUnited States Tax Court · 1950
- United States v. FlynnCourt of Appeals for the Second Circuit · 1954
- Bercaw v. CommissionerCourt of Appeals for the Fourth Circuit · 1948
- Hans Zimmerman and Clara Zimmerman, Apellants v. United States of America and District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
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3Cited by7 opinions
- La Staiti v. CommissionerUnited States Tax Court · 1980
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- Cappuccilli v. CommissionerUnited States Tax Court · 1980
- Century Motor Coach v. CommissionerUnited States Tax Court · 1995
- Kittle v. CommissionerUnited States Tax Court · 1975
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