109 T.C. No. 18
UNITED STATES TAX COURT
JOYCE ASTON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26105-95. Filed December 4, 1997.
On July 5, 1991, banking regulators seized the
assets of the Bank of Commerce and Credit
International, S.A. (BCCI, S.A.), including funds
that petitioner (a United Kingdom citizen and U.S.
resident) deposited at BCCI, S.A.'s Isle of Man
branch (IOMB). Petitioner's account was insured
for loss up to 15,000 pounds sterling by the Isle
of Man Depositor's Compensation Scheme. Petitioner
filed a claim against BCCI, S.A. for her funds.
At all relevant times BCCI, S.A. maintained an
agency office in Los Angeles.
Petitioner deducted $185,493.79 as a loss from
an insolvent financial institution pursuant to sec.
165(l)(1), I.R.C., on her 1991 U.S. Federal income
tax return. The $185,493.79 represented the final
balance of her IOMB account, less the 15,000 pounds
sterling insurance.
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