Jon T. Stephens and Susanne Stephens v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that taxpayers who repay embezzled funds might be “entitled to a deduction in the year in which the funds are repaid”
• stating that “Congress intended these ‘provision[s] for the denial of the deduction for payments in these situations which are deemed to violate public policy ... to be all inclusive.’ ” (alterations in original) (citation omitted)
• finding restitution to be compensatory where sentencing judge characterized it as intended to “get [the victim] its money back”
• “Although Tellier and Tank Truck Rentals were both decided pursuant to Tax Code provisions relating to business expenses, the test for nondeductibility enunciated in those opinions is applicable to loss deductions under Section 165.”
• taxpayer placed on probation on condition that he make restitution payment

Source: CourtListener parenthetical corpus (CC0).