Tax Research M E M O R A N D U M To: Student From: Paula Partner…

Question Answered step-by-step Tax Research M E M O R A N D U M To: Student From: Paula Partner… Tax Research M E M O R A N D U M To: Student From: Paula Partner Date: May 30, 2022 Subject:  Semyon Ovechkin’s Potential Loss             I have recently acquired a new client named Semyon Ovechkin.  Semyon is a native of Russia and has come to the United States to play hockey.  While in Russia, Semyon was an avid gambler and wanted to continue his habit here in the States.  To that end, in the off season Semyon had an illegal gambling business operated from his home.            Recently the police caught word of his gambling operation.  Following the tips they received, the police obtained and executed a search warrant on Semyon’s home and surrounding premises.  In executing the warrant, the police seized gambling paraphernalia and $200,000 in cash.  Realizing the jig was up, Semyon consented to forfeit the cash that had been seized to the state.             It was with respect to the $200,000 cash seized by the authorities that Semyon came to see me.  His question was whether the cash which he voluntarily conceded to the state could be claimed as a loss under Section 165.  I would like you to research this issue and do two things.  First, draft a brief letter to Semyon indicating the results of your research and whether or not the loss is allowable.  Second, respond back to me with a reply memo indicating how you interpreted the law you found to Semyon’s situation.  I have already undertaken the research in this project and have found a case which will provide you with all you need to find your answer.  The case is listed below.  It and the code provision provided will be the exclusive sources for your letter and memo.            Semyon’s address is 1234 S City Blvd., Salt Lake City, UT 84646.            Please use our business address in corresponding with Semyon: Partner & Associates, 1323 Harrison Blvd., Ogden, UT 84403.SourcesIRC § 165Edman Hackworth (TC Memo. 2004-173).Rubric   Law Social Science Tax law ACTG 3400 Share QuestionEmailCopy link Comments (0)