Alsop v. Commissioner
United States Tax Court
Held: (1) That petitioner is not entitled to a loss deduction for embezzled royalties since no part of these royalties was ever included by her in any Federal income tax return; and (2) that the amount of the embezzled royalties recovered by litigation constitutes taxable income to petitioner in the year of recovery.
1Opinion of the Court
Ajrundell, Judge:
Respondent determined deficiencies in income tax for the calendar years 1952, 1953, and 1954 in the amounts of $3,295.25, $8,574.52, and $2,976.35, respectively.
The issues are: (1) Whether petitioner is entitled to a loss deduction in connection with embezzled royalties that were never included by her as income in any Federal income tax return; and (2) whether the amounts of the embezzled royalties that were recovered constitute taxable income to the petitioner in the year of recovery.
FINDINGS OF FACT.
The stipulated facts are so found and are incorporated herein by this…
2Cases cited11 opinions
- Helvering v. GowranSupreme Court of the United States · 1937
- O'Meara v. CommissionerUnited States Tax Court · 1947
- Alison v. United StatesSupreme Court of the United States · 1952
- Teleservice Company of Wyoming Valley v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Teleservice Co. of Wyoming Valley v. CommissionerUnited States Tax Court · 1957
6 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Estate of Leavitt v. CommissionerUnited States Tax Court · 1988
- Borg v. CommissionerUnited States Tax Court · 1968
- Gerling International Ins. Co. v. CommissionerUnited States Tax Court · 1986
- O'Brien v. CommissionerUnited States Tax Court · 1961
- Alsop v. CommissionerUnited States Tax Court · 1960
13 more not listed; retrieve them via the Exa API.