Legal Opinion

Sammons v. Commissioner

United States Tax Court

Decided July 28, 1986No. Docket No. 21133-82UnpublishedCited by 36 opinions

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

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Neely v. CommissionerUnited States Tax Court · 1985
  3. 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
  4. United States v. MitchellSupreme Court of the United States · 1971
  5. Kaplan v. CommissionerUnited States Tax Court · 1965

10 more not listed; retrieve them via the Exa API.

3Cited by36 opinions

  1. ESTATE OF DAVIS v. COMMISSIONERUnited States Tax Court · 1998
  2. Myron G. Sammons and Dorothy Sammons, Petitioners-Appellees/cross-Appellants v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Ninth Circuit · 1988
  3. Trans City Life Ins. Co. v. CommissionerUnited States Tax Court · 1996
  4. Booth v. CommissionerUnited States Tax Court · 1997
  5. Citron v. CommissionerUnited States Tax Court · 1991

31 more not listed; retrieve them via the Exa API.

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