Licht v. Commissioner
United States Board of Tax Appeals
In July 1931, a fire occurred in the principal place of business of petitioner's husband, resulting in loss and damage to property. Petitioner's husband was insured against loss from fire.
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In July 1931, a fire occurred in the principal place of business of petitioner's husband, resulting in loss and damage to property. Petitioner's husband was insured against loss from fire. Question arose as to the causes of the fire and the New York Board of Fire Underwriters instituted hearings that extended to December 30, 1931. However, the facts do not show conclusively that in that year all the insurers disclaimed liability or that the institution of hearings indicated that hope of recovery from the insurers was too remote for the insured to conclude that he was covered by insurance in…
1Opinion of the Court
*1098OPINION.
HakRon:
The question in this proceeding is as follows: Was any loss sustained in the year 1933 as a result of the fire that occurred in 1931 at the place of business of petitioner’s husband? It is respondent’s contention that the loss was not sustained in 1933, but that it was sustained in 1931. The respondent’s argument is that the loss in question was deductible in 1931 under the provisions of section 23 (e)1 (Revenue Acts of 1928 and 1932), because the loss which occurred in that year, when property was damaged or destroyed by fire, was not “compensated for by insurance or…
2Cases cited1 opinion
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
3Cited by18 opinions
- Hudock v. CommissionerUnited States Tax Court · 1975
- Gale v. CommissionerUnited States Tax Court · 1963
- Estate of Scofield v. CommissionerCourt of Appeals for the Sixth Circuit · 1959
- Kunsman v. CommissionerUnited States Tax Court · 1967
- Estate of Levi T. Scofield, Douglas F. Schofield, Trustee, Mary Jane Scofield Demmon (Nee Mary Jane Scofield), Roy C. Demmon and Mary Scofield Demmon, Josephine Scholfield Thompson, Edward W. Thompson and Josephine S. Thompson, Douglas F. Schofield Trust, Douglas F. Schofield, Trustee, Douglas F. Schofield and Mary D. Schofile, Field, Schofield Building Land Trust, Douglas F. Schofield, Trustee v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Estate of Levi T. Scofield, Douglas F. Schofield, TrusteeCourt of Appeals for the Sixth Circuit · 1959
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