MARY FRANCES ALLEN V. COMMISSIONER
16 T.C. 163 (1951)
NATURE OF THE CASE: This was a dispute over the deduction for a lost brooch. Allen (P)
filed a petition contesting the disallowance of a deduction for the loss of a diamond brooch
by theft
FACTS: Allen (P) owned a brooch, which she lost in some unknown manner while visiting the
Metropolitan Museum of Art. P cannot prove that the brooch was stolen. All that P knows is
that it disappeared and was never found or returned. P sought to deduct this loss but the
IRS disallowed the deduction.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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