Legal Opinion

HARTLEY v. COMMISSIONER

United States Tax Court

Decided September 19, 1977No. Docket No. 1305-76UnpublishedCited by 1 opinion

Petitioners made cash advances to a contractor to enable him to purchase building materials for the construction of their home. The contractor purchased part of the materials on credit creating a mechanics lien on petitioners' property which they were required to discharge. The contractor defaulted on the construction contract and absconded with part of the cash advances. Held, petitioners suffered a deductible theft loss under sec. 165(c)(3), I.R.C. 1954.

1Opinion of the Court

ALLEN HARTLEY and BETTY HARTLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

HARTLEY v. COMMISSIONER

Docket No. 1305-76.

United States Tax Court

T.C. Memo 1977-343; 1977 Tax Ct. Memo LEXIS 125; 36 T.C.M. (CCH) 1381;

September 19, 1977, Filed

Petitioners made cash advances to a contractor to enable him to purchase building materials for the construction of their home. The contractor purchased part of the materials on credit creating a mechanics lien on petitioners' property which they were required to discharge. The contractor defaulted on the construction contract and absconded with…

2Cases cited15 opinions

  1. Edwards v. BrombergCourt of Appeals for the Fifth Circuit · 1956
  2. Monteleone v. CommissionerUnited States Tax Court · 1960
  3. Allen v. CommissionerUnited States Tax Court · 1951
  4. Vietzke v. CommissionerUnited States Tax Court · 1961
  5. Jones v. CommissionerUnited States Tax Court · 1955

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3Cited by1 opinion

  1. James M. Urtis and Gaetana R. Urtis v. CommissionerUnited States Tax Court · 2013

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