Mark D. Collins 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.

• “[T]axing an embezzler on his illicit gains accords with the fair administration of the tax law because it removes the anomaly of having the income of an honest individual taxed while the similar gains of a criminal are not.”
• taxpayer who stole racing tickets that generated net gambling losses had theft income, not gain from wagering transactions under section 165(d)
• taxpayer who stole racing tickets that generated net gambling losses had theft income, not gain from wagering transactions under section 165(d)
• taxpayer who stole racing tickets that generated net gambling losses had theft income, not gain from wagering transactions under section 165(d)
• “Loans are identified by the mutual .understanding between the borrower and lender of the obligation to repay and a bona fide intent on the borrower’s part to repay the acquired funds.”
• section 165(d) \only allows gambling losses to offset gambling winnings\

Source: CourtListener parenthetical corpus (CC0).