- 20 - argument, we therein stated "that we have several times denied taxpayers deductions for losses due to inflation, on grounds that the tax law is not written to account for inflation." Id. at 1363.10 We further determined that nominal gain is taxable because of (1) the doctrine "that Congress has the power and authority to establish the dollar as a unit of legal value with respect to the determination of taxable income, independent of any value the dollar might also have as a commodity" (citations omitted), and (2) the doctrine of common interpretation, which defines income on the basis of the understanding of a lay person, not an economist. Id. at 1364, 1366. We held in the Commissioner's favor, concluding that (1) the taxpayers' use of the Consumer Price Index (including any other method measuring inflation) to calculate taxable income is irrelevant, and (2) nominal gain is taxable income. Id. at 1363-1364; see also Sibla v. Commissioner, 68 T.C. 422, 430-431 (1977) (holding that the taxpayer was neither entitled to a deduction nor any other adjustment to his gross income because of the fact that the value of a dollar may have declined in relation to silver or gold), affd. 611 F.2d 1260 (9th Cir. 1980); Gajewski v. Commissioner, 67 T.C. 181, 194-195 (1976) (holding that the value of the dollar is "irrelevant for purposes of computing * * * [a taxpayer's] taxable income", and "for purposes of the tax law, 10 We note that when Congress desires to take inflation into account, it does so by statute. See, e.g., secs. 1(f), 151.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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