Kloosterhouse v. Commissioner
United States Tax Court
Petitioner provided money to a corporation that was in need of financial help. In return for part of the funds, petitioner received 50 percent of the stock of the corporation. Despite the infusion of funds, the company went out of business. Held, petitioner is not entitled to a deduction under sec. 165, I.R.C. 1954, because he has not proved that his losses were due to theft as defined under the relevant state law.
1Opinion of the Court
GEORGE KLOOSTERHOUSE AND LOUISE D. KLOOSTERHOUSE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Kloosterhouse v. Commissioner
Docket No. 261-77.
United States Tax Court
T.C. Memo 1981-481; 1981 Tax Ct. Memo LEXIS 259; 42 T.C.M. (CCH) 970; T.C.M. (RIA) 81481;
September 2, 1981.
Petitioner provided money to a corporation that was in need of financial help. In return for part of the funds, petitioner received 50 percent of the stock of the corporation. Despite the infusion of funds, the company went out of business. Held, petitioner is not entitled to a deduction under sec. 165, I.R.C.…
2Cases cited15 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Andresen v. StateCourt of Special Appeals of Maryland · 1975
- Edwards v. BrombergCourt of Appeals for the Fifth Circuit · 1956
- Monteleone v. CommissionerUnited States Tax Court · 1960
- Paine v. CommissionerUnited States Tax Court · 1975
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