Rod Warren Ink v. Commissioner
United States Tax Court
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
- Henry Schwartz Corp. v. CommissionerUnited States Tax Court · 1973
- P.R. Farms, Inc. v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1987
- Asphalt Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1969
- Jerome Castree Interiors, Inc. v. CommissionerUnited States Tax Court · 1975
- Marine v. CommissionerUnited States Tax Court · 1989
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