Halliburton Co. v. Commissioner
United States Tax Court
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
TANNENWALD, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes of $27,953, $11,126,409, and $20,907,748 for the taxable years 1977, 1978, and 1979, respectively. After concessions, the issues for decision are whether petitioner is entitled to deduct losses in 1979 pursuant to section 1651 for the expropriation of stock and debt by the Iranian government in 1979, or alternatively as worthless securities and debt under sections 165(g) and 166(a), respectively, both of which issues turn essentially upon the existence of a reasonable prospect of recovery as of December…
2Cases cited26 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Dames & Moore v. ReganSupreme Court of the United States · 1981
- Boehm v. CommissionerSupreme Court of the United States · 1945
- 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
- Ramsay Scarlett & Co. v. CommissionerUnited States Tax Court · 1974
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3Cited by22 opinions
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- Aston v. Comm'rUnited States Tax Court · 1997
- Continental Illinois Corp. v. CommissionerUnited States Tax Court · 1990
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