Legal Opinion
Jon T. Stephens and Susanne Stephens v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided June 11, 1990No. 824, Docket 89-4116PublishedCited by 21 opinions
1Opinion of the Court
CONBOY, District Judge:
Petitioners Jon T. Stephens and Susanne Stephens 1 appeal from the decision of the Tax Court, Stephens v. Commissioner, 93 T.C. 108 (1989), determining a deficiency in their federal income tax for the year 1984 in the amount of $28,397.34. The sole issue before us on appeal is whether the Tax Court correctly determined that Stephens was not entitled to a loss deduction, pursuant to Section 165 of the Internal Revenue Code of 1954, 26 U.S.C. § 165 (1982), 2 for a restitution payment he made in 1984 to the Raytheon Company (“Raytheon”), on the ground that allowance of the…
2Cases cited26 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Commissioner v. TellierSupreme Court of the United States · 1966
- Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958
- Lilly v. CommissionerSupreme Court of the United States · 1952
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
21 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Jess Kraft and Barbara Kraft v. United StatesCourt of Appeals for the Sixth Circuit · 1993
- Mark D. Collins v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
- Marshall M. Chernin Ida Raye Chernin, Cross-Appellants/appellees v. United States of America, Appellant/cross-AppelleeCourt of Appeals for the Eighth Circuit · 1998
- Talley Industries Inc. Consolidated Subsidiaries v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1997
- Fresenius Medical Care Holdings, Inc. v. United StatesCourt of Appeals for the First Circuit · 2014
16 more not listed; retrieve them via the Exa API.