Smith v. Commissioner
United States Tax Court
Held: 1. Urban renewal agency's payment of precasualty value for property destroyed by flood, acquired after the flood pursuant to the Relocation Act of 1970, Pub. L. 91-646, constitutes compensation "by insurance or otherwise" within the meaning of section 165(a), I.R.C. 1954. 2. Deductions in excess of amounts conceded by respondent for gasoline taxes and interest paid denied.
1Opinion of the Court
Dawson, Judge:
This case was assigned to and heard by Special Trial Judge Murray H. Falk pursuant to the provisions of section 7456(c) of the Internal Revenue Code1 and Rules 180 and 181, Tax Court Rules of Practice and Procedure.2 The Court agrees with and adopts his opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Falk, Special Trial Judge:
Respondent determined deficiencies of $481.20, $746, $368.49, and $715.23, respectively, in petitioners’ 1969,1970,1971, and 1972 Federal income taxes. We must determine the amount of a casualty loss deductible under section 165 suffered…
2Cases cited2 opinions
- Shanahan v. CommissionerUnited States Tax Court · 1974
- Estate of Bryan v. CommissionerUnited States Tax Court · 1980
3Cited by2 opinions
- Estate of Dickerson v. CommissionerUnited States Tax Court · 1997
- Smith v. CommissionerUnited States Tax Court · 1981