Stephens v. Commissioner
United States Tax Court
Petitioner husband was convicted of criminal violations of Federal statutes governing fraudulent activities. He was sentenced to prison and fined on some counts. On one count, he was sentenced to prison and fined, but the sentence was suspended and he was placed on probation on condition that he make restitution of the amounts obtained as the result of his fraud.
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Petitioner husband was convicted of criminal violations of Federal statutes governing fraudulent activities. He was sentenced to prison and fined on some counts. On one count, he was sentenced to prison and fined, but the sentence was suspended and he was placed on probation on condition that he make restitution of the amounts obtained as the result of his fraud. Held, the deduction of the restitution payment is governed by sec. 165(c)(2), I.R.C. 1954, and not sec. 162(a), I.R.C.Held, further, the standards governing the application of sec. 162(f), I.R.C., may be utilized in determining…
1Opinion of the Court
Jon T. Stephens and Susanne Stephens, Petitioners v. Commissioner of Internal Revenue, Respondent
Stephens v. Commissioner
Docket No. 6997-88
United States Tax Court
93 T.C. 108; 1989 U.S. Tax Ct. LEXIS 107; 93 T.C. No. 11;
July 26, 1989; As corrected August 8, 1989 July 26, 1989, Filed
Decision will be entered under Rule 155.
Petitioner husband was convicted of criminal violations of Federal statutes governing fraudulent activities. He was sentenced to prison and fined on some counts. On one count, he was sentenced to prison and fined, but the sentence was suspended and he was placed on probation…
2Cases cited13 opinions
- United States v. LemireCourt of Appeals for the D.C. Circuit · 1983
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Holt v. CommissionerUnited States Tax Court · 1977
- William E. Bailey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1985
- Glen D. Wood, Karen Kraak Wood, and Karen Eslinger Wood v. United StatesCourt of Appeals for the Fifth Circuit · 1989
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