PULVERS V. COMMISSIONER 407 F.2d 838 (9th Cir. 1969) CASE BRIEF

PULVERS V. COMMISSIONER
407 F.2d 838 (9th Cir. 1969)
NATURE OF THE CASE: This was a dispute over a casualty loss deduction. Pulvers (P) challenged an order of the United States Tax Court, which affirmed the determination that Ps might have suffered a fluctuation in value of their property, but incurred no actual loss and therefore could not take a deduction for other casualty loss on their federal income tax return.
FACTS: Pulvers (P) lived in the hills and a nearby landslide ruined nearby homes. Because of P's location in the danger zone the value of their home was impacted by the fear of other landslides. P took a casualty loss on their tax return. The IRS denied the deduction because no physical injury had yet occurred.

ISSUE:


RULE OF LAW:


HOLDING AND DECISION:


LEGAL ANALYSIS:





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