Nailing down a definition for "Treasure Trove"

Technical topics regarding tax preparation.
#1
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Treasure Reg §1.61-14 "Miscellaneous items of gross income" says
Treasure trove, to the extent of its value in United States currency, constitutes gross income for the taxable year in which it is reduced to undisputed possession.

Is the term "treasure trove" defined anywhere in the Code, Regs, Rulings, Publications, or any other "authoritative" IRS source? Or is the term defined only in several states and foreign countries, and differently among those states and countries, too...?
 

#2
LW25  
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I did a quick search but didn’t “find” much.

However, a “trove” (rhymes with “stove”) (a noun, short for “treasure trove”) is a discovery; a “find”; a valuable collection.

Under English common law, “trover” (as a noun) was a common law action to recover the value of goods wrongfully converted by another person to the wrongdoer’s own use.

The words “trove” and “trover” came to the English language from the Middle French verb “trover” (which means “to find”). The modern French verb is spelled “trouver” (roughly, pronounced “troo-vay”).

"J'ai trouvé cet argent-ci dans la rue" ("I found this money in the street"). That would be a treasure trove.

This isn’t a definition of treasure trove itself, but it's an old Revenue Ruling similar to the more authoritative Treasury regulation quoted above:

The finder of treasure-trove is in receipt of taxable income, for Federal income tax purposes, to the extent of its value in United States currency, for the taxable year in which it is reduced to undisputed possession.


--Rev. Rul. 61, 1953-1 C.B. 17.
 

#3
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Merci, mon ami.
 

#4
LW25  
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Ce n'est rien.
 

#5
Nilodop  
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Someone with the time and resources to track down these citations might find a definition. Or not.
Petitioner urges that our interpretation would lead to incongruous results. A person who finds an Irish Sweepstakes ticket, which turns out to be a loser later that day, first would he charged with income from treasure trove and then would suffer a nondeductible wagering loss, a result petitioner finds fantastic. We are not amazed. Petitioner has described the correct tax treatment of treasure trove. See sec. 165(d); Cesarini v. United States [69-1 USTC ¶ 9270], 296 F.Supp. 3 (N.D. Ohio 1969), affd. [70-2 USTC ¶ 9509], 428 F.2d 812 (6th Cir. 1970); sec. 1.61-14(a), Income Tax Regs.; see also Rev. Rul. 61, 1953-1 C.B. 17; Rosenak, "Taxation of Found Property and Other Windfalls", 20 U. Chi. L. Rev. 748 (1952).
 

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I was sorta interested in nailing down - or not - the "treasure" aspect of the income tax definition. Like, as in, would the front grill from a '50 Ford found in the woods behind my house be a "treasure" that would make its value, upon the grill being discovered and kept, a taxable item?
 

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Harry, don't give the IRS any ideas! What about Finders keepers, losers weepers? There are times when IRS should just mind their own business. When you find the grill to a '50 Ford in the woods is one of those times. :D
 

#8
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But I had no taxable income in the year I found the grill, even if I include a coupla hundred bucks for the value of the "treasure" item, and if I report that income, then my tax basis in the restored car will be that much bigger in the year I sell it, if I ever do... The door is open, and I want to go through it! ;) 8-) ;)
 

#9
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NYU outline, 2010 https://www.law.nyu.edu/sites/default/f ... _2010.docx

It discusses section 61, reg. 1.61-14, and a 2010 Ohio district court case called Cesarini. https://law.justia.com/cases/federal/di ... 3/1982804/

This article requires paying, I think. https://heinonline.org/HOL/LandingPage? ... 1560713547

https://www.hklaw.com/en/insights/publi ... codes-taxi

OP should come back with a summary conclusion. :D

Happy Father's Day.
 

#10
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If memory serves, there was an extensive discussion in the old days over at TaxAlmanac to which I contributed regarding treasure troves. I think it had something to do with money found in the walls of a remodeled house. Possibly paintings by masters found behind or under other paintings may also have been come up in the wide ranging discussion. Or, those may have just been part of the things I read when I did all the definition hunting back then.
 

#11
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Summary conclusion, driven pretty much by the hypothetical scenario I had to design to get this discussion off the ground in the first place: Whether it's a "treasure" or not, I'm pretty sure the Ford grill - and probably the bumper, too - will be *very* valuable when I report their discovery on my tax return, the tax return where the income recognized from finding the parts, "treasure" or not, will not increase my tax bill...

The Cesarini case seems to be all about the timing of the recognition and the nature of the income recognized, and not at all about the definition of "treasure trove." For the Ford parts, I don't need "treasure," I only need "trove."

And (as PVCC says, "if memory serves") her name was Jerry and we were in the back seat of a '50 Ford Coupé... ;) :oops: ;)
 

#12
MWPXYZ  
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No discussion on treasure trove should omit the carve out for baseballs:

https://lawreview.vermontlaw.edu/wp-con ... Vol-33.pdf
 

#13
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If I find a million dollars, I would happily pay the tax on it.
 


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