Popa v. Commissioner

73 T.C. 130 (1980)

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Popa v. Commissioner

United States Tax Court
73 T.C. 130 (1980)

Rich Walter headshot
  • Written by Rich Walter, JD

Facts

During the Vietnam War, Justin Popa (plaintiff) was an American businessman based in Saigon, South Vietnam. In April 1975, Popa left Saigon on a business trip to Thailand. A day or two later, Saigon was suddenly overrun by enemy forces, and all United States citizens were evacuated. Popa was unable to return to Saigon and had no reasonable hope of ever recovering his Saigon property or its value. Popa claimed a casualty-loss tax deduction for his property loss. The commissioner of internal revenue (commissioner) (defendant) disallowed the deduction, determining that Popa’s loss was not a casualty loss as defined by § 165(c)(3) of the federal tax code. Popa filed a petition challenging the commissioner’s determination.

Rule of Law

Issue

Holding and Reasoning (Sterrett, J.)

Dissent (Fay, J.)

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Casebooks

Federal Income Tax

Key Terms

  • Ejusdem Generis [from the Latin “of the same kind”] A rule of statutory interpretation that requires general terms, when following a specific list of words or things, be read to be similar to those specific words or things. This rule ensures that general terms are read in context with more specific ones.
  • Casualty LossThe loss of property from a sudden and unexpected event or accident.
  • Tax deductibleAn expense eligible for subtraction from taxable income.

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