Continental Illinois Corp. v. Commissioner
United States Tax Court
Petitioner, a calendar-year taxpayer, had property expropriated by the government of Iran in 1979. Held, even though petitioner retained Iranian deposit accounts, it had no legal right to offset its expropriation claims against such accounts, any practical possibility of setoff was no more than a bargaining chip which did not give rise to a reasonable prospect of recovery as of Dec. 31, 1979, and this case is otherwise controlled by Halliburton Co. v. Commissioner, 93 T.C.…
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Petitioner, a calendar-year taxpayer, had property expropriated by the government of Iran in 1979. Held, even though petitioner retained Iranian deposit accounts, it had no legal right to offset its expropriation claims against such accounts, any practical possibility of setoff was no more than a bargaining chip which did not give rise to a reasonable prospect of recovery as of Dec. 31, 1979, and this case is otherwise controlled by Halliburton Co. v. Commissioner, 93 T.C. 758 (1989), so that petitioner was entitled to a deduction for losses sustained during the taxable year.
1Opinion of the Court
Continental Illinois Corp., Petitioner v. Commissioner of Internal Revenue, Respondent
Continental Illinois Corp. v. Commissioner
Docket No. 5931-83. (Iranian Loss Issue)
United States Tax Court
94 T.C. 165; 1990 U.S. Tax Ct. LEXIS 7; 94 T.C. No. 12;
February 28, 1990February 28, 1990, Filed
An order will be entered holding for petitioner on the severed expropriation issue.
Petitioner, a calendar-year taxpayer, had property expropriated by the government of Iran in 1979. Held, even though petitioner retained Iranian deposit accounts, it had no legal right to offset its expropriation claims against…
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- National City Bank of NY v. Republic of ChinaSupreme Court of the United States · 1955
- First National City Bank v. Banco Nacional De CubaSupreme Court of the United States · 1972
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