Legal Opinion

Maloof v. Commissioner

United States Tax Court

Decided November 10, 1975No. Docket No. 4615-72Published

Prior to Dec. 7, 1941, petitioner conducted a business in China of importing, exporting, and contracting for the manufacture of linens and other goods. He sustained a war loss of assets of this business, consisting largely of inventory.

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Prior to Dec. 7, 1941, petitioner conducted a business in China of importing, exporting, and contracting for the manufacture of linens and other goods. He sustained a war loss of assets of this business, consisting largely of inventory. In 1966, he recovered an amount with respect to the lost inventory and realized a gain under sec. 1333(3), I.R.C. 1954. A replacement fund was established under sec. 1033(a)(2) and, within the required time, petitioner used the fund to establish a manufacturing business dealing with the same sort of goods as before. The assets of the new business included a…

1Opinion of the Court

Fred Maloof, Petitioner v. Commissioner of Internal Revenue, Respondent

Maloof v. Commissioner

Docket No. 4615-72

United States Tax Court

65 T.C. 263; 1975 U.S. Tax Ct. LEXIS 34;

November 10, 1975, Filed

Decision will be entered under Rule 155.

Prior to Dec. 7, 1941, petitioner conducted a business in China of importing, exporting, and contracting for the manufacture of linens and other goods. He sustained a war loss of assets of this business, consisting largely of inventory. In 1966, he recovered an amount with respect to the lost inventory and realized a gain under sec. 1333(3), I.R.C. 1954. A…

2Cases cited16 opinions

  1. Massillon-Cleveland-Akron Sign Co. v. CommissionerUnited States Tax Court · 1950
  2. Loco Realty Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
  3. Haberland v. CommissionerUnited States Board of Tax Appeals · 1932
  4. Wheeler v. CommissionerUnited States Tax Court · 1972
  5. Willis v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1932

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