Legal Opinion

Peyton v. Commissioner

United States Board of Tax Appeals

Decided March 1, 1928No. Docket No. 31208PublishedCited by 13 opinions

Damages paid by petitioner on account of personal injuries to other persons resulting from the operation of his automobile are not allowable as a deduction under section 214(a)(6) of the Revenue Act of 1924.

1Opinion of the Court

*1130OPINION.

Milliken :

It is the contention of the petitioner that the sum paid by him and for the purpose indicated is a deductible loss under section 214(a) (6) of the Iievenue Act of 1924, which provides as follows :

Losses sustained during the taxable year of property not connected with the trade or business * * * if arising from fires, storms, shipwreck, or other casualty, or from theft, and if not compensated for by insurance or otherwise. * * *

Counsel for petitioner insists that the loss claimed is deductible under the above section of the statute, and relies upon the cases of Shearer v.…

2Cited by13 opinions

  1. Cornelius v. CommissionerUnited States Tax Court · 1971
  2. Tarsey v. CommissionerUnited States Tax Court · 1971
  3. William C. Dosher v. United States of America (Internal Revenue Service)Court of Appeals for the Fifth Circuit · 1984
  4. Stern v. CareyDistrict Court, N.D. Ohio · 1953
  5. C. W. Stoll v. CommissionerUnited States Tax Court · 1946

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