- 20 -
165(a) allows for a deduction for any loss sustained during the
taxable year and not compensated for by insurance or otherwise.
The amount of the deduction is determined using the adjusted
basis of the property. Sec. 165(b). Petitioner has not
established the date of the loss, nor his basis in the Stables.7
For these reasons, petitioner is not entitled to a loss
deduction.
To reflect the above concessions and holdings,
Decision will be entered
under Rule 155.
7 It appears that after petitioner went to court to contest
the Dec. 1967 transfer to Singer, the court's dismissal left
petitioner with an uncollectible debt. The loss would be that of
the debt, not the Stables, and would have occurred in 1968 at the
earliest, not in 1967.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Last modified: May 25, 2011