Pulvers v. Commissioner
United States Tax Court
A 1963 landslide did no physical damage to petitioners' residence property but did involve the sole access street and resulted in an immediate diminution in its fair market value. Held, that the drop in value was a fluctuation caused by temporary buyer resistance and the Code does not authorize casualty loss deductions for wavering values. Stowers v. United States, 169 F.Supp. 246 (S.D. Miss. 1958), distinguished.
1Opinion of the Court
FORRESTER, Judge:
Tbe respondent lias determined deficiencies in petitioners’ income taxes for the years 1960 and 1963 in the respective amounts of $770.68 and $1,964.06. Concessions have been made and certain items in the statutory deficiency notice have not been put into issue so that the only issue remaining for our decision is whether petitioners are entitled to a casualty loss deduction within the meaning of section 165(c) (3) of the Internal Eevenue Code of 19541 for the year 1963. The year 1960 is before us because of a claimed net operating loss carryback from the year 1963, said…
2Cases cited7 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Weiss v. WeinerSupreme Court of the United States · 1929
- The Citizens Bank of Weston v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
- Citizens Bank of Weston v. CommissionerUnited States Tax Court · 1957
- Peterson v. CommissionerUnited States Tax Court · 1958
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