Popa v. Commissioner
United States Tax Court
Petitioner maintained a home in Saigon. While he was away on a short business trip, the city fell to the North Vietnamese. He was never able to return and consequently claimed a $ 12,691 casualty loss on his 1975 return for the value of his goods left behind.
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Petitioner maintained a home in Saigon. While he was away on a short business trip, the city fell to the North Vietnamese. He was never able to return and consequently claimed a $ 12,691 casualty loss on his 1975 return for the value of his goods left behind. Held: The unprecedented suddenness with which the United States left Saigon and Saigon's subsequent seizure by the North Vietnamese resulted in petitioner's loss of property in a casualty comparable to those set forth in sec. 165(c)(3), I.R.C. 1954. His inability to specify the precise manner in which his property was destroyed or…
1Opinion of the Court
Justin Popa, Petitioner v. Commissioner of Internal Revenue, Respondent
Popa v. Commissioner
Docket No. 3144-78
United States Tax Court
73 T.C. 130; 1979 U.S. Tax Ct. LEXIS 33;
October 22, 1979, Filed
Decision will be entered under Rule 155.
Petitioner maintained a home in Saigon. While he was away on a short business trip, the city fell to the North Vietnamese. He was never able to return and consequently claimed a $ 12,691 casualty loss on his 1975 return for the value of his goods left behind. Held: The unprecedented suddenness with which the United States left Saigon and Saigon's subsequent…
Also in this document: Concurrence; Dissent.
2Cases cited19 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Banco Nacional De Cuba v. SabbatinoSupreme Court of the United States · 1964
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Burnet v. HoustonSupreme Court of the United States · 1931
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