- 9 - pension plans or annuities,3 the issue decided in Hellermann v. Commissioner, 77 T.C. 1361 (1981), involved the same principles. In Hellermann v. Commissioner, supra, the taxpayers argued that gain that was realized from the sale of property should be adjusted to take into account the inflation that occurred during the ownership of the property. We disagreed. First, we relied upon “the well-established 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.” Id. at 1364. For this proposition, we relied upon 3This Court has consistently denied taxpayers deductions for losses due to inflation and has repeatedly rejected the argument that inflation is a proper ground for failing to report income. See Sibla v. Commissioner, 68 T.C. 422, 430-431 (1977), affd. 611 F.2d 1260 (9th Cir. 1980); Gajewski v. Commissioner, 67 T.C. 181, 195 (1976), affd. without published opinion 578 F.2d 1383 (8th Cir. 1978); Bartley v. Commissioner, T.C. Memo. 1998-322; Ruben v. Commissioner, T.C. Memo. 1987-277; Downing v. Commissioner, T.C. Memo. 1983-97; Warren v. Commissioner, T.C. Memo. 1982-696; Notter v. Commissioner, T.C. Memo. 1982-96; Cunninghman v. Commissioner, T.C. Memo. 1981-365; Milkowski v. Commissioner, T.C. Memo. 1981-225; Crossland v. Commissioner, T.C. Memo. 1976- 59. Other courts have reached the same conclusions when faced with similar situations. See Stelly v. Commissioner, 804 F.2d 868, 870 (5th Cir. 1986) (“The * * * [taxpayers’] contention that they are entitled to an inflation adjustment to their interest income is plainly incorrect.”); Birkenstock v. Commissioner, 646 F.2d 1185, 1186 (7th Cir. 1981) (“The market price of gold in terms of dollars is * * * irrelevant to the determination of * * * taxable income”), affg. T.C. Memo. 1979-201; Bates v. United States, 108 F.2d 407, 408 (7th Cir. 1939) (attaching no “significance to the statutory gold content of the dollar as a factor in the determination of gain from the sale of capital assets”); Daugherty v. United States, 1 Cl. Ct. 216, 218 (1983) (taxpayer not entitled to “inflation factor” deduction).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011