Elliot Virgil Wilkerson - Page 17

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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                   
               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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