Richey v. Commissioner
United States Tax Court
Petitioner invested $ 15,000 in a scheme to duplicate United States $ 100 bills. Petitioner actively participated in the scheme and rendered assistance in the duplicating process.
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Petitioner invested $ 15,000 in a scheme to duplicate United States $ 100 bills. Petitioner actively participated in the scheme and rendered assistance in the duplicating process. His cohorts in the duplicating operation swindled petitioner out of the $ 15,000. Held, petitioner is not entitled to a $ 15,000 loss deduction under section 165(c)(2) or (3) of the Code of 1954, since allowance of the deduction would constitute a frustration of sharply defined public policy against counterfeiting obligations of the United States.
1Opinion of the Court
Fisher, Judge:
Respondent determined a deficiency in income tax against petitioners for tbe taxable year 1955 in tbe amount of $4,084.21.
Tbe principal issue is whether petitioner, who actively participated in a scheme to duplicate United States currency, and in connection therewith was swindled out of $15,000, is entitled to a deduction of that amount under section 165(c) (2) or (8) of the Code of 1954, or whether such deduction should be disallowed as constituting a frustration of sharply defined public policy.
findings of fact.
Some of the facts are stipulated and are incorporated herein by…
2Cases cited10 opinions
- Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958
- Commissioner v. SullivanSupreme Court of the United States · 1958
- Fuller v. CommissionerUnited States Tax Court · 1953
- Fuller v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Jerry Rossman Corporation v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1949
5 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Holt v. CommissionerUnited States Tax Court · 1977
- Mazzei v. CommissionerUnited States Tax Court · 1974
- Reffett v. CommissionerUnited States Tax Court · 1963
- Blackman v. CommissionerUnited States Tax Court · 1987
- Wusich v. CommissionerUnited States Tax Court · 1960
18 more not listed; retrieve them via the Exa API.