T.C. Memo. 2003-129
UNITED STATES TAX COURT
RUDOLPH H. BEAVER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10305-01. Filed May 2, 2003.
For 1993, P claimed a $2,816,540 capital loss on
his sale of H stock, believing that the loss in the
value of the stock was caused by the market. In 1997,
P discovered that the loss in the value of the stock
was attributable to a theft. In 1997, P claimed the
$2,816,540 loss as a theft loss. At trial, P did not
establish that any portion of the capital loss claimed
in 1993 remained for carryover after that year.
Held: P is not entitled to deduct in 1997 any of
the loss as a theft loss. In that P has failed to
establish that any portion of the capital loss remained
for carryover after 1993, P has not established that he
had in 1997 any basis in the H stock that would allow
him to deduct for 1997 a theft loss with respect to the
H stock.
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