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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 loss
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