Floyd C. and Marian L. Hoffman v. Commissioner of Internal Revenue

David J. Harris

Case Conclusion Date:September 22, 2009

Practice Area:Tax

Outcome:Case Settled By IRS's Withdrawal Of Assessment

Description:Petitioners, Ponzi scheme victims, took a theft loss deduction on their 2000 tax return, using phantom gains and income upon which they previously paid tax to calculate their theft loss basis. The IRS opposed their doing so. A trial was held and prior to the Tax Court's issuing an opinion, the IRS withdrew its objection and assessment in light of its post trial Revenue Ruling 2009-09 to accommodate the Madoff Ponzi scheme victims.