Feinstein v. Commissioner
United States Tax Court
Deductions -- Losses From Worthlessness of Securities -- War Losses -- I. R. C. 1939, Secs. 23 (k) (2) and 127. -- Held, petitioners have not met their burden of establishing that certain Rumanian bonds became worthless in 1947.
1Opinion of the Court
OPINION.
Tietjens, Judge:
Petitioners’ theory of their case may thus be summarized: They owned 1,000,000 French francs value of the bonds described in our Findings of Fact; these bonds became worthless as a war loss in 1941 upon the commencement of war between the United States and Rumania as provided in section 127 of the Internal Revenue Code of 1939; they “recovered” the bonds in 1945 in which year the fair market value of the bonds was at least $26,000; and, finally, the bonds became worthless in 1947, the year before us.
The “war loss” in 1941 is conceded by respondent, but he contends that…
2Cases cited5 opinions
- Solt v. CommissionerUnited States Tax Court · 1952
- Kenmore v. CommissionerUnited States Tax Court · 1952
- Kenmore v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953
- San Joaquin Brick Co. v. Commissioner of Int. Rev.Court of Appeals for the Ninth Circuit · 1942
- Von Dattan v. CommissionerUnited States Tax Court · 1954
3Cited by24 opinions
- Crown v. CommissionerUnited States Tax Court · 1981
- Denver & R. G. W. R. Co. v. CommissionerUnited States Tax Court · 1959
- Pachella v. CommissionerUnited States Tax Court · 1961
- American Offshore, Inc. v. CommissionerUnited States Tax Court · 1991
- Herbert P. Weinmann v. United StatesCourt of Appeals for the Second Circuit · 1960
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