For Your Data Allen V. Commissioner Illustration Brief
October 14, 2016
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Allen v. Commissioner representative brief
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16 T.C. 163, 1951 U.S. Tax Ct.
CASE SYNOPSIS: Petitioner private filed a petition contesting respondent Commissioner of Internal Revenue's adjustment disallowing a deduction for the loss of a diamond brooch past times theft, accounting for a deficiency of $ 1,800.16 inward petitioner's income taxation for 1945.
FACTS: Petitioner owned a diamond brooch having a fair marketplace value of $ 2,400. Petitioner went to New York City, N.Y., to view the Museum of Art. At closing time, petitioner was on the stairwell of the museum amongst over 5,000 people. When the closing betoken was sounded, the visitors streamed downwards the stairway. Upon reaching the bottom 2 or 3 steps, petitioner realized that she did non convey the brooch on her coat, which she had worn to the museum. Petitioner notified the Museum too filed a police pull study stating that the brooch was stolen from her coat. Petitioner filed a taxation provide for 1945, too nether a "Schedule of Gains too Losses," she claimed a loss of $ 2,400 for the brooch. Respondent filed a notice of deficiency, disallowing the deduction on the solid seat down that the data submitted was non sufficient to institute theft inward connecter amongst the loss of the brooch. Petitioner contested the finding, too the courtroom sustained respondent's findings. The courtroom held that petitioner could non evidence that the pivot was stolen, failing to satisfy her burden of proof.
CONCLUSION: The courtroom entered a determination for respondent, sustaining its determination.
FACTS: Petitioner owned a diamond brooch having a fair marketplace value of $ 2,400. Petitioner went to New York City, N.Y., to view the Museum of Art. At closing time, petitioner was on the stairwell of the museum amongst over 5,000 people. When the closing betoken was sounded, the visitors streamed downwards the stairway. Upon reaching the bottom 2 or 3 steps, petitioner realized that she did non convey the brooch on her coat, which she had worn to the museum. Petitioner notified the Museum too filed a police pull study stating that the brooch was stolen from her coat. Petitioner filed a taxation provide for 1945, too nether a "Schedule of Gains too Losses," she claimed a loss of $ 2,400 for the brooch. Respondent filed a notice of deficiency, disallowing the deduction on the solid seat down that the data submitted was non sufficient to institute theft inward connecter amongst the loss of the brooch. Petitioner contested the finding, too the courtroom sustained respondent's findings. The courtroom held that petitioner could non evidence that the pivot was stolen, failing to satisfy her burden of proof.
CONCLUSION: The courtroom entered a determination for respondent, sustaining its determination.
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Interested inward learning how to acquire the transcend grades inward your law schoolhouse classes? Want to larn how to study smarter than your competition? Interested inward transferring to a high ranked school?