HARTLEY v. COMMISSIONER
United States Tax Court
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
- Edwards v. BrombergCourt of Appeals for the Fifth Circuit · 1956
- Monteleone v. CommissionerUnited States Tax Court · 1960
- Allen v. CommissionerUnited States Tax Court · 1951
- Vietzke v. CommissionerUnited States Tax Court · 1961
- Jones v. CommissionerUnited States Tax Court · 1955
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3Cited by1 opinion
- James M. Urtis and Gaetana R. Urtis v. CommissionerUnited States Tax Court · 2013