UNGAR v. COMMISSIONER

Docket No. 32054.

18 T.C. 688 (1952)

GEORGE UNGAR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 30, 1952.


Attorney(s) appearing for the Case

Nathaniel Rothstein, Esq., for the petitioner.

William G. O'Neill, Esq., for the respondent.


The Commissioner determined a deficiency of $3,728.24 in income tax of the petitioner for 1948. The only issue for decision is whether the petitioner is entitled to a deduction of $9,000 for 1948 representing a loss by theft within the meaning of section 23 (e) (3).

FINDINGS OF FACT.

The petitioner resides in Brooklyn, New York, and filed his return for 1948 with the collector of internal revenue for the first district of New York.

The petitioner...

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