Petition of the day

Thepetition of the day is:

Issues:(1) Whether funds forfeited pursuant to a criminal conviction are deductible in cases in which such forfeited funds (in contrast with a simultaneously imposed punitive fine) are earmarked and used to compensate victims of the underlying criminal offense; and (2) whether the U.S. Court of Appeals for the Federal Circuit’s holding in this case that such forfeited funds are not deductible conflicts with the U.S. Court of Appeals for the 2nd Circuit’s holding inStephens v. Commissioner of Internal Revenueand the U.S. Court of Appeals for the 1st Circuit’s holding inFresenius Medical Care Holdings, Inc. v. United States.