Popa v. Commissioner
United States Tax Court
73 T.C. 130 (1979)
Relevant factsFree
American businessman Justin Popa (plaintiff) was in Thailand when Saigon suddenly fell to enemy forces in April 1975, and he was evacuated with all other U.S. citizens, permanently losing any realistic hope of recovering his Saigon property or its value; he claimed a casualty-loss deduction, which the tax commissioner (defendant) disallowed for failing to prove the loss fell within the statute's specific categories.
IssueFree
Whether a taxpayer's loss of property due to a sudden, cataclysmic, and devastating event is generally a deductible casualty loss under federal tax law.