Legal Opinion

Henry L. And Frances O. Hills v. Commissioner of Internal Revenue

Court of Appeals for the Eleventh Circuit

Decided November 15, 1982No. 81-7668PublishedCited by 18 opinions

1Opinion of the Court

GOLDBERG, Circuit Judge:

Section 165 of the Internal Revenue Code of 1954 allows, as a general rule, deductions for “losses ... not compensated for by insurance or otherwise.”1 In this appeal we are presented with a question of first impression in this circuit; we are called upon to decide whether a voluntary election not to file an insurance claim for a theft loss precludes a casualty loss deduction under this section.

1. INTRODUCTION

A. Facts

Henry and Frances Hills, taxpayer-appellees, own a vacation home near Dahlonega, Georgia. About April 1, 1976, a thief disturbed the solitude of their…

2Cases cited23 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Mohasco Corp. v. SilverSupreme Court of the United States · 1980
  3. Pollock v. Farmers' Loan & Trust Co.Supreme Court of the United States · 1895
  4. City of Milwaukee v. IllinoisSupreme Court of the United States · 1981
  5. United States v. Kirby Lumber CoSupreme Court of the United States · 1931

18 more not listed; retrieve them via the Exa API.

3Cited by18 opinions

  1. Edgar Alan Rickard, D/B/A Trader Publications of Alabama v. Auto Publisher, Inc., a CorporationCourt of Appeals for the Eleventh Circuit · 1984
  2. National Wildlife Federation v. John O. Marsh, Secretary of the ArmyCourt of Appeals for the Eleventh Circuit · 1983
  3. Atlanta Athletic Club v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1993
  4. Dixon F. Miller v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984
  5. In Re BulgerUnited States Bankruptcy Court, M.D. Alabama · 1988

13 more not listed; retrieve them via the Exa API.

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