Legal Opinion
Webb v. Internal Revenue Service of the United States
District Court, D. Massachusetts
Decided May 25, 1993No. Civ. A. No. 90-11009-YPublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM AND ORDER
YOUNG, District Judge.
The main issue to be decided on this motion for summary judgment is whether funds embezzled from disbursements of a federal storm disaster relief loan are taxable income to the embezzler. The plaintiff, Frederick L. Webb (“Webb”), contends that, since he always intended to repay the embezzled loan funds, they are properly categorized for tax purposes as a loan and should not have been assessed as income to him in the year of embezzlement. The Internal Revenue Service (“IRS”) responds that an embezzler’s intentions are irrelevant and that…
2Cases cited13 opinions
- Robert C. Hahn v. Francis W. SargentCourt of Appeals for the First Circuit · 1975
- James v. United StatesSupreme Court of the United States · 1961
- Rutkin v. United StatesSupreme Court of the United States · 1952
- Angelus Milling Co. v. CommissionerSupreme Court of the United States · 1945
- United States v. William J. Rochelle, Jr., Trustee in Bankruptcy for John Milton Addison, BankruptCourt of Appeals for the Fifth Circuit · 1967
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3Cited by3 opinions
- Webb v. Internal Revenue Service of the United StatesCourt of Appeals for the First Circuit · 1994
- Sun v. CommissionerCourt of Appeals for the Fifth Circuit · 2018
- Webb v. IRSCourt of Appeals for the First Circuit · 1994