- 16 - labor union of which petitioner was a member, constituted compensation for services under section 61(a)(1). Petitioner’s theory, however, is that this Court concluded that he forfeited certain rights that constitute property of value for which he is entitled to a loss deduction. Petitioner’s contention is misplaced. Petitioner’s alleged forfeiture of rights is not the type of loss contemplated by section 165(c)(3). In fact, petitioner’s own testimony revealed that he characterizes the forfeiture of rights as a job-related expense. Moreover, petitioner presented no evidence that his alleged personal loss resulted from either a theft or a sequence of events normally associated with a casualty; that is, sudden, unexpected, or unusual events causing a considerable destructive force to property where the resulting direct and proximate damage causes a loss similar to that arising from a fire, storm, or shipwreck. White v. Commissioner, 48 T.C. 430, 434-435 (1967); see Landy v. Commissioner, T.C. Memo. 1979- 354 (taxpayer not entitled to personal casualty loss deduction for the loss of driving privileges). Even assuming arguendo that petitioner’s forfeiture of rights under the collective bargaining agreement constitutes a personal casualty loss or theft, petitioner would not be entitled to a deduction for such loss or theft because the alleged lossPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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