- 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