Sammons v. Commissioner
United States Tax Court
Petitioner husband paid $12,000 for a race horse which was never delivered. Efforts by petitioner and his attorney in 1977 to obtain delivery of horse or recovery of payment established that horse would not be delivered or money recovered.
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Petitioner husband paid $12,000 for a race horse which was never delivered. Efforts by petitioner and his attorney in 1977 to obtain delivery of horse or recovery of payment established that horse would not be delivered or money recovered. Held, under California law where horse was purchased theft includes loss by embezzlement and petitioners are entitled to a theft loss deduction under section 165. In 1977, petitioner gave two art dealers $140,000 with which to purchase for him a specific collection of Indian artifacts and deliver collection to a museum. Later petitioner discovered that the…
1Opinion of the Court
MYRON G. SAMMONS AND DOROTHY SAMMONS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sammons v. Commissioner
Docket No. 21133-82.
United States Tax Court
T.C. Memo 1986-318; 1986 Tax Ct. Memo LEXIS 292; 51 T.C.M. (CCH) 1568; T.C.M. (RIA) 86318;
July 28, 1986; AFFIRMED IN PART AND REVERSED IN PART January 27, 1988
Petitioner husband paid $12,000 for a race horse which was never delivered. Efforts by petitioner and his attorney in 1977 to obtain delivery of horse or recovery of payment established that horse would not be delivered or money recovered.
Held, under California law where horse…
2Cases cited15 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Neely v. CommissionerUnited States Tax Court · 1985
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- United States v. MitchellSupreme Court of the United States · 1971
- Kaplan v. CommissionerUnited States Tax Court · 1965
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- Booth v. CommissionerUnited States Tax Court · 1997
- Citron v. CommissionerUnited States Tax Court · 1991
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