WOLFSON v. COMMISSIONER
United States Tax Court
Petitioner transferred a diamond engagement ring and a ring guard to G, a woman he was dating. About a week later G decided to terminate their relationship. Petitioner sued for the cost of the diamond engagement ring and the ring guard and was awarded a default judgment for the full amount in 1976. This judgment created an enforceable obligation on G to pay petitioner this amount. In 1977, petitioner obtained execution of this judgment, but it was returned nulla bona.
Read the full summary
Petitioner transferred a diamond engagement ring and a ring guard to G, a woman he was dating. About a week later G decided to terminate their relationship. Petitioner sued for the cost of the diamond engagement ring and the ring guard and was awarded a default judgment for the full amount in 1976. This judgment created an enforceable obligation on G to pay petitioner this amount. In 1977, petitioner obtained execution of this judgment, but it was returned nulla bona. Held: Petitioner has failed to prove that his debt became worthless in 1976, and so no deduction is allowable for 1976. Sec.…
1Opinion of the Court
JACK WOLFSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
WOLFSON v. COMMISSIONER
Docket No. 9132-78
United States Tax Court
T.C. Memo 1982-698; 1982 Tax Ct. Memo LEXIS 63; 45 T.C.M. (CCH) 244; T.C.M. (RIA) 82698;
November 29, 1982.
Petitioner transferred a diamond engagement ring and a ring guard to G, a woman he was dating. About a week later G decided to terminate their relationship. Petitioner sued for the cost of the diamond engagement ring and the ring guard and was awarded a default judgment for the full amount in 1976. This judgment created an enforceable obligation on G to…
2Cases cited12 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Boehm v. CommissionerSupreme Court of the United States · 1945
- Dallmeyer v. CommissionerUnited States Tax Court · 1950
- Crown v. CommissionerUnited States Tax Court · 1981
- Sherman v. CommissionerUnited States Tax Court · 1952
7 more not listed; retrieve them via the Exa API.