Lattimore v. Commissioner
United States Tax Court
Held: This Court has no jurisdiction to rule upon claims for refund for any year for which a deficiency has not been determined. Petitioner discovered in 1955 a claimed casualty loss, the insurance recovery on which was not determined until 1959. Held: petitioner has failed to demonstrate that the loss is deductible in 1956, the only year before us for which respondent has determined a deficiency.
1Opinion of the Court
Anne E. Lattimore v. Commissioner.
Lattimore v. Commissioner
Docket No. 85037.
United States Tax Court
T.C. Memo 1962-75; 1962 Tax Ct. Memo LEXIS 233; 21 T.C.M. (CCH) 393; T.C.M. (RIA) 62075;
April 4, 1962
Held: This Court has no jurisdiction to rule upon claims for refund for any year for which a deficiency has not been determined.
Petitioner discovered in 1955 a claimed casualty loss, the insurance recovery on which was not determined until 1959. Held: petitioner has failed to demonstrate that the loss is deductible in 1956, the only year before us for which respondent has determined a deficiency.
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2Cases cited4 opinions
- Dial v. CommissionerUnited States Tax Court · 1955
- Merchants Fire Assurance Corporation v. Ann E. LattimoreCourt of Appeals for the Ninth Circuit · 1959
- Diversified Services, Inc. v. United StatesDistrict Court, S.D. Florida · 1961
- Lattimore v. Merchants Fire Assurance Corp.District Court, N.D. California · 1957