English (United Kingdom)

https://curated-unify.zendy.io/wp-json/zendy-region/v1/featured_content/oa?rat=en

https://curated-unify.zendy.io/wp-json/zendy-region/v1/highlighted_journal/

Zendy Plus

Presents the access of premium content as premium feature

Premium Content

Presents the keyphrase highlighting as premium feature

Keyphrase Highlighting

Presents the summarisation as premium feature

Summarisation

Insights

Presents the pdf analysis as premium feature

PDF Analysis

Presents the zaia usage as premium feature

ZAIA

Zendy Tools

Zendy Open

Section 165(c)(3) of the Internal Revenue Code provides for a deduction of "losses of property not connected with a trade or business, if such losses arise from fire, storm, shipwreck, or other casualty" and if, under section 165(a), they are "not compensated for by insurance or otherwise."1 The casualty loss provision is of ancient lineage in the tax law; the first such deduction, for losses arising from "fires [or] shipwreck," was included in the income tax provision of the 1867 internal revenue statute.2 In 1870 the deduction was extended to cover losses from "floods." 3 The 1894 income tax, held unconstitutional by the Supreme Court,4 reworded the deduction to cover losses from "fires, storms, and shipwreck."5 Similar language was used in the 1913 Act." The term "other casualty," source of the doctrinal complications which are the subject of this comment, was first included in 1916.7 There is virtually no legislative history on any of these casualty loss provisions. The most likely explanation is simply that Congress was actuated by a notion of fairness; it sought to reduce the tax burden on a person whose income does not reflect his economic position because his assets have been destroyed during the taxable year. The archetypical case is that of the taxpayer whose uninsured home and personal property are destroyed as a result of natural disaster; his income during the

The Casualty Loss Deduction and Consumer Expectation: Section 165(c) (3) of the Internal Revenue Code