Blackman v. Commissioner
United States Tax Court
P set fire to his wife's clothes, and that fire spread to and destroyed his residence. P deducted the amount of the loss as a casualty loss within the meaning of sec. 165(c)(3), I.R.C. 1954. Held: 1. P is not entitled to a deduction for a casualty loss. 2. P failed to prove that his failure to file a timely return was due to reasonable cause within the meaning of sec. 6651(a), I.R.C. 1954. 3. P is not liable for the addition to tax under sec. 6653(a), I.R.C 1954, since he…
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P set fire to his wife's clothes, and that fire spread to and destroyed his residence. P deducted the amount of the loss as a casualty loss within the meaning of sec. 165(c)(3), I.R.C. 1954. Held: 1. P is not entitled to a deduction for a casualty loss. 2. P failed to prove that his failure to file a timely return was due to reasonable cause within the meaning of sec. 6651(a), I.R.C. 1954. 3. P is not liable for the addition to tax under sec. 6653(a), I.R.C 1954, since he had reason for claiming the deduction for the casualty loss.
1Opinion of the Court
Biltmore Blackman, Petitioner v. Commissioner of Internal Revenue, Respondent
Blackman v. Commissioner
Docket No. 21436-84
United States Tax Court
88 T.C. 677; 1987 U.S. Tax Ct. LEXIS 35; 88 T.C. No. 38;
March 24, 1987. March 24, 1987, Filed
Decision will be entered under Rule 155.
P set fire to his wife's clothes, and that fire spread to and destroyed his residence. P deducted the amount of the loss as a casualty loss within the meaning of sec. 165(c)(3), I.R.C. 1954. Held:
1. P is not entitled to a deduction for a casualty loss.
2. P failed to prove that his failure to file a timely return was due…
2Cases cited18 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958
- Fuller v. CommissionerUnited States Tax Court · 1953
- Fuller v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Heyn v. CommissionerUnited States Tax Court · 1966
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