Legal Opinion

Rod Warren Ink v. Commissioner

United States Tax Court

Decided May 11, 1989No. Docket No. 43425-86Published

P was a personal holding company. During P's fiscal years 1979, 1980, and 1981, P's manager embezzled funds. P did not discover the embezzlement until fiscal year 1982. Held, for purposes of the personal holding company tax provisions, secs. 541-547, sec. 165(e) precludes deduction of theft losses prior to the year of discovery.

1Opinion of the Court

Rod Warren Ink, A Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent

Rod Warren Ink v. Commissioner

Docket No. 43425-86

United States Tax Court

92 T.C. 995; 1989 U.S. Tax Ct. LEXIS 72; 92 T.C. No. 62;

May 11, 1989. May 11, 1989, Filed

Decision will be entered for the respondent.

P was a personal holding company. During P's fiscal years 1979, 1980, and 1981, P's manager embezzled funds. P did not discover the embezzlement until fiscal year 1982. Held, for purposes of the personal holding company tax provisions, secs. 541-547, sec. 165(e) precludes deduction of theft losses prior…

2Cases cited12 opinions

  1. Henry Schwartz Corp. v. CommissionerUnited States Tax Court · 1973
  2. P.R. Farms, Inc. v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1987
  3. Asphalt Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1969
  4. Jerome Castree Interiors, Inc. v. CommissionerUnited States Tax Court · 1975
  5. Marine v. CommissionerUnited States Tax Court · 1989

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