Legal Opinion

Michael Korn v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided October 23, 1975No. 74-1660PublishedCited by 9 opinions

1Opinion of the Court

OPINION

Before MERRILL and WRIGHT, Circuit Judges, and FERGUSON, * District Judge. EUGENE A. WRIGHT, Circuit Judge:

Taxpayer appeals a Tax Court decision which sustained the Commissioner’s assessment of an income tax deficiency for the taxable years 1966, 1967, and 1968. The appeal presents the question whether 1965, the year chosen by the taxpayer to claim the loss of certain property located in Poland, was the appropriate year for such a deduction under 26 U.S.C. § 165(a). If the loss were properly deductible in 1965, then the taxpayer was entitled to the net operating loss carryover…

2Cases cited4 opinions

  1. Burnet v. HoustonSupreme Court of the United States · 1931
  2. Boehm v. CommissionerSupreme Court of the United States · 1945
  3. National Brass Works, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1953
  4. Estate of Frank Fuchs, Deceased, Edith Fuchs, and Edith Fuchs, Surviving Wife Individually v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969

3Cited by9 opinions

  1. Halliburton Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991
  2. Halliburton Co. v. CommissionerUnited States Tax Court · 1989
  3. Continental Illinois Corp. v. CommissionerUnited States Tax Court · 1990
  4. Elghanian v. Comm'rUnited States Tax Court · 2005
  5. Continental Illinois Corp. v. CommissionerUnited States Tax Court · 1990

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