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Section A: Personal Use Property Date of Purchase
Property A: Clothes washer 1981
Property B: Lawnmower 1984
Property C: Books, notes, and awards1 1964-1970
Property D: Lawnseeder 1982
Properties
A B C D
Cost or other basis $330 $240 $7,150 $90
Insurance or other reimbursement -0- -0- -0- -0-
FMV before casualty/theft 300 100 6,700 75
FMV after casualty/theft -0- -0- 500 -0-
Casualty or theft loss 300 100 6,200 75
Total: $6,675 (but reported by petitioner as $6,625)
Section B: Business Use Property Date of Purchase
Property A: Law Library 1974
Property B: Office Furniture 1983
Property C: Office Equipment 1974-1985
Property D: Professional Research2 1974-present
Properties
A B C D
Cost or other basis $1,403 $4,276 $1,040 $12,670
Insurance or other reimbursement -0- -0- -0- -0-
FMV before casualty/theft 10,000 1,500 2,000 20,000
FMV after casualty/theft 1,000 200 350 -0-
Casualty or theft loss 1,403 4,276 1,040 12,670
Total: $19,389 (but reported by petitioner as $15,156, a discrepancy
unexplained in the record)
1The category of “books, notes” represents petitioner’s
classroom notes and law books (case books, horn books, and
Gilbert’s outlines) from law school, which he attended from 1967
to 1970. The category of “awards” represent plaques and trophies
“and things like that” that petitioner received in the mid-1960s
in recognition of his service as a local school board member.
2The category of “professional research” represents client
files and includes petitioner's work product.
Respondent’s disposition of petitioner’s claim for refund is
discussed infra in subdivision E of our findings of fact.
D. Petitioner’s Indictment and Conviction
In March 1996, petitioner was indicted under 18 U.S.C. sec.
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Last modified: May 25, 2011