Cornelius v. Commissioner
United States Tax Court
Petitioners' personal residence and its contents were totally destroyed by fire in March 1964. The fair market value of the house and its contents immediately after the fire was zero. The cost basis of the household contents was $ 55,568.37. The depreciation (or reduction in value by use) of the household contents was $ 13,047.40. Petitioners paid $ 210 to build a fence around the destroyed house.
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Petitioners' personal residence and its contents were totally destroyed by fire in March 1964. The fair market value of the house and its contents immediately after the fire was zero. The cost basis of the household contents was $ 55,568.37. The depreciation (or reduction in value by use) of the household contents was $ 13,047.40. Petitioners paid $ 210 to build a fence around the destroyed house. Petitioners received $ 4,492.20 from the insurance company as additional living expenses under the provisions of their homeowners insurance policy. Held: 1. The fair market value (cost less…
1Opinion of the Court
Dawson, Judge:
Respondent determined the following deficiencies in petitioners’ Federal income taxes:
Tear Deficiency
1961_$3,108. 97
1962 _ 409.35
1964 - 1, 873.12
There is no dispute as to the amount of the casualty loss for the house, an appraisal fee paid to the insurance adjusters, and the cost of debris removal. Three issues are presented for our decision: (1) What was the fair market value of the 'household contents of petitioners’ home immediately before the fire of March 28,1964 ? (2) Are the expenses ($210) incurred by petitioners to build a fence around the destroyed house allowable as…
2Cases cited13 opinions
- Helvering v. OwensSupreme Court of the United States · 1939
- Millsap v. CommissionerUnited States Tax Court · 1966
- I. Hal Millsap, Jr., and Frances Millsap v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1968
- McAnarney v. Newark Fire InsuranceNew York Court of Appeals · 1928
- George E. Conner and Dorothy P. Conner v. United StatesCourt of Appeals for the Fifth Circuit · 1971
8 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Pfalzgraf v. CommissionerUnited States Tax Court · 1977
- Ruben v. CommissionerUnited States Tax Court · 1987
- Bruhns v. CommissionerUnited States Tax Court · 1991
- COLTER v. COMMISSIONERUnited States Tax Court · 2001
- Corcoran v. CommissionerUnited States Tax Court · 1976
13 more not listed; retrieve them via the Exa API.