Legal Opinion

Cowarde v. Commissioner

United States Tax Court

Decided August 10, 1976No. Docket No. 560-75Unpublished

Respondent disallowed certain deductions for lack of substantiation. Held, petitioner failed to carry burden of proof with respect to casualty loss deduction. Held further, Taxpayer is entitled to an interest expense deduction in the amount of $606.78 in accordance with respondent's concessions.

1Opinion of the Court

MARTHA S. COWARDE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Cowarde v. Commissioner

Docket No. 560-75

United States Tax Court

T.C. Memo 1976-246; 1976 Tax Ct. Memo LEXIS 156; 35 T.C.M. (CCH) 1066; T.C.M. (RIA) 760246;

August 10, 1976, Filed

Respondent disallowed certain deductions for lack of substantiation. Held, petitioner failed to carry burden of proof with respect to casualty loss deduction. Held further, Taxpayer is entitled to an interest expense deduction in the amount of $606.78 in accordance with respondent's concessions.

Martha S. Cowarde, pro se.

Stephen R. Takeuchi, for…

2Cases cited2 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cowarde v. CommissionerUnited States Tax Court · 1968

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