Naegle v. Commissioner

Ninth Circuit

Naegle v. Commissioner

378 F.2d 397

CourtCourt of Appeals for the Ninth Circuit

DecidedMay 16, 1967

DocketNos. 20877, 20877A

StatusPublished

Cited by2 cases

This text of 378 F.2d 397 (Naegle v. Commissioner) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Naegle v. Commissioner, 378 F.2d 397 (9th Cir. 1967).

Pincite

Opinion

PER CURIAM.

The petitions for review in this case involve deficiencies in income tax in the total amount of $16,718.57 against Grant E. Naegle for the years 1956 and 1960, and in the total amount of $249.11 against his wife, Norma, for the years 1959 and 1960. Decisions of the Tax Court upholding the deficiencies were entered November 10, 1965. The questions presented for our determination, both factual in nature, are (1) whether the Tax Court correctly held that sums embezzled in 1956 were includible in taxpayer’s income in that year; (2) whether the Tax Court correctly held that taxpayer had failed to prove net operating losses in prior years, deductions for charitable contributions and repayment of embezzled funds, and that Norma Naegle was entitled to claim for herself both deductions for the two minor children of the parties.

For the reasons set forth by the Tax Court in its Memorandum Findings of Fact and Opinion, filed August 6, 1965, the decisions are affirmed.

Free access — add to your briefcase to read the full text and ask questions with AI

PER CURIAM.

The petitions for review in this case involve deficiencies in income tax in the total amount of $16,718.57 against Grant E. Naegle for the years 1956 and 1960, and in the total amount of $249.11 against his wife, Norma, for the years 1959 and 1960. Decisions of the Tax Court upholding the deficiencies were entered November 10, 1965. The questions presented for our determination, both factual in nature, are (1) whether the Tax Court correctly held that sums embezzled in 1956 were includible in taxpayer’s income in that year; (2) whether the Tax Court correctly held that taxpayer had failed to prove net operating losses in prior years, deductions for charitable contributions and repayment of embezzled funds, and that Norma Naegle was entitled to claim for herself both deductions for the two minor children of the parties.

For the reasons set forth by the Tax Court in its Memorandum Findings of Fact and Opinion, filed August 6, 1965, the decisions are affirmed.

Cite This Page — Counsel Stack

Bluebook (online)

378 F.2d 397, Counsel Stack Legal Research, https://law.counselstack.com/opinion/naegle-v-commissioner-ca9-1967.

Opinion

Related

Cite This Page — Counsel Stack