Mulholland v. Commissioner
United States Board of Tax Appeals
Damages, costs and expenses paid by petitioner on account of personal injuries to another person, resulting from the operation of his automobile by his minor son on a pleasure trip, are not allowable as a deduction from gross income under section 214(a)(6) of the Revenue Act of 1921.
1Opinion of the Court
OPINION.
Littleton :
Petitioner claims that he is entitled to a deduction as a loss of the amount paid for personal injuries caused by his auto*1333mobile under the provisions of section 214 (a) (6) of the Kevenue Act of 1921, which provides that in computing net income there shall be allowed as deductions “losses sustained during the taxable year of property not connected with the trade or business * * ⅜ if arising from fires, storms, shipwreck, or other casualty, or from theft, and if not compensated for by insurance or otherwise.”
Petitioner relies upon Shearer v. Anderson, 16 Fed. (2d) 995, and…
2Cited by9 opinions
- Millsap v. CommissionerUnited States Tax Court · 1966
- Murphy v. CommissionerUnited States Tax Court · 1967
- William C. Dosher v. United States of America (Internal Revenue Service)Court of Appeals for the Fifth Circuit · 1984
- Stern v. CareyDistrict Court, N.D. Ohio · 1953
- C. W. Stoll v. CommissionerUnited States Tax Court · 1946
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