Legal Opinion

Halliburton Co. v. Commissioner

United States Tax Court

Decided December 26, 1989No. Docket No. 9797-86Published

Petitioner, a calendar year taxpayer, had property expropriated by the government of Iran in 1979. Held, since petitioner had no reasonable prospect of recovery as of Dec. 31, 1979, it was entitled to a deduction for losses sustained during the taxable year.

1Opinion of the Court

Halliburton Co., Petitioner v. Commissioner of Internal Revenue, Respondent

Halliburton Co. v. Commissioner

Docket No. 9797-86

United States Tax Court

93 T.C. 758; 1989 U.S. Tax Ct. LEXIS 157; 93 T.C. No. 61;

December 26, 1989December 26, 1989, Filed

Decision will be entered under Rule 155.

Petitioner, a calendar year taxpayer, had property expropriated by the government of Iran in 1979. Held, since petitioner had no reasonable prospect of recovery as of Dec. 31, 1979, it was entitled to a deduction for losses sustained during the taxable year.

David T. Harvin, Donald F. Wood, David Gerger, and…

2Cases cited27 opinions

  1. United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
  2. Dames & Moore v. ReganSupreme Court of the United States · 1981
  3. Boehm v. CommissionerSupreme Court of the United States · 1945
  4. William F. Callejo, Individually and as Trustee, and Adelfa B. Callejo, as Trustee v. Bancomer, S.A.Court of Appeals for the Fifth Circuit · 1985
  5. Ramsay Scarlett & Co. v. CommissionerUnited States Tax Court · 1974

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