Carpenter v. Commissioner

T.C. Memo. 1966-228 (1966)

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Carpenter v. Commissioner

United States Tax Court
T.C. Memo. 1966-228 (1966)

Facts

Nancy Carpenter (plaintiff) placed her diamond ring in a glass of ammonia next to the kitchen sink in order to clean the ring. Nancy’s husband, William Carpenter (plaintiff), did not know that the ring was in the glass. William emptied the glass into the sink and activated the garbage disposal. The ring was completely destroyed by the garbage disposal. Nancy deducted the value of the ring as a casualty loss from her income. The commissioner of internal revenue (commissioner) (defendant) found that the accidental destruction of the ring was not a casualty loss, and the Carpenters petitioned the United States Tax Court for a redetermination.

Rule of Law

Issue

Holding and Reasoning (Withey, J.)

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