Nichols v. Commissioner
United States Tax Court
Held, petitioners have shown on this record by clear evidence that they paid out sums of money to enter into certain tax-avoidance schemes by reason of misrepresentations of M. Eli Livingstone, that they relied upon those misrepresentations and would not have paid out such sums otherwise, that they were thus swindled by Livingstone, and that they are accordingly entitled to deductions for theft losses in 1959, the year in which Livingstone's fraud was discovered by them.
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Held, petitioners have shown on this record by clear evidence that they paid out sums of money to enter into certain tax-avoidance schemes by reason of misrepresentations of M. Eli Livingstone, that they relied upon those misrepresentations and would not have paid out such sums otherwise, that they were thus swindled by Livingstone, and that they are accordingly entitled to deductions for theft losses in 1959, the year in which Livingstone's fraud was discovered by them. Sec. 165(a), (c)(3), and (e), I.R.C. 1954.
1Opinion of the Court
Perry A. Nichols and Inez Nichols, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Nichols v. Commissioner
Docket Nos. 91061, 91062, 91063, 91064, 91065, 91066
United States Tax Court
43 T.C. 842; 1965 U.S. Tax Ct. LEXIS 111;
March 24, 1965, Filed March 24, 1965, Filed
Decisions will be entered under Rule 50.
Held, petitioners have shown on this record by clear evidence that they paid out sums of money to enter into certain tax-avoidance schemes by reason of misrepresentations of M. Eli Livingstone, that they relied upon those misrepresentations and would not have paid out…
2Cases cited17 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Goodstein v. CommissionerUnited States Tax Court · 1958
- Edwards v. BrombergCourt of Appeals for the Fifth Circuit · 1956
- Joseph H. Bridges and Lillier J. Bridges v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
- Bridges v. CommissionerUnited States Tax Court · 1963
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