Viehweg v. Commissioner
United States Tax Court
Petitioners invested in limited partnerships that engaged in transactions identical to and controlled by the Court's opinion in Julien v. Commissioner, 82 T.C. 492 (1984), and Glass v. Commissioner, 87 T.C. 1087 (1986), currently on appeal. Held, petitioners are not entitled to theft loss deductions for the out-of-pocket amounts of their investments.
1Opinion of the Court
OPINION
COHEN, Judge:
Respondent determined deficiencies in petitioners’ income tax as follows:
Petitioner Docket No. Year Deficiency
Viehweg 29646-81 1977 $39,038.78
1978 30,418.00
Morfit 28211-82 1975 135,015.54
1976 54,270.99
1977 92,383.95
1978 51,773.18
Finneran 13397-84 1976 32,411.00
1977 63,648.00
1978 49,359.00
Petitioner Docket No. Year Deficiency
Foreman 284-85 1977 $23,182.61
1978 25,027.08
Hudson 36285-85 1977 53,559.00
1978 29,611.00
1972 Nauta 41882-86 890.21
1975 20,075.00
1976 18,415.57
1977 34,263.77
After concessions, the sole issue for decision is whether petitioners are entitled to theft loss…
2Cases cited14 opinions
- Luman v. CommissionerUnited States Tax Court · 1982
- Glass v. CommissionerUnited States Tax Court · 1986
- Ramsay Scarlett & Co. v. CommissionerUnited States Tax Court · 1974
- Ramsay Scarlett and Company, Inc. v. Commissioner of Internal Revenue, Baltimore Stevedoring Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1975
- Paine v. CommissionerUnited States Tax Court · 1975
9 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Marine v. CommissionerUnited States Tax Court · 1989
- Chao v. CommissionerUnited States Tax Court · 1989
- Beecroft v. CommissionerUnited States Tax Court · 1997
- Greenberg Bros. Pshp. 12 v. CommissionerUnited States Tax Court · 1998
- Bukove v. CommissionerUnited States Tax Court · 1991
21 more not listed; retrieve them via the Exa API.