For Your Data Allen V. Commissioner Example Brief
November 07, 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 yesteryear 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 dot was sounded, the visitors streamed downwards the stairway. Upon reaching the bottom ii 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 together with filed a law written report stating that the brooch was stolen from her coat. Petitioner filed a taxation provide for 1945, together with nether a "Schedule of Gains together with Losses," she claimed a loss of $ 2,400 for the brooch. Respondent filed a notice of deficiency, disallowing the deduction on the footing that the data submitted was non sufficient to institute theft inward connectedness amongst the loss of the brooch. Petitioner contested the finding, together with 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 dot was sounded, the visitors streamed downwards the stairway. Upon reaching the bottom ii 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 together with filed a law written report stating that the brooch was stolen from her coat. Petitioner filed a taxation provide for 1945, together with nether a "Schedule of Gains together with Losses," she claimed a loss of $ 2,400 for the brooch. Respondent filed a notice of deficiency, disallowing the deduction on the footing that the data submitted was non sufficient to institute theft inward connectedness amongst the loss of the brooch. Petitioner contested the finding, together with 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 piece of employment yesteryear grades inward your law schoolhouse classes? Want to acquire how to study smarter than your competition? Interested inward transferring to a high ranked school?