Henry Deletis, Jr. - Page 20

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          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                     
               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.                                                      

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Last modified: May 25, 2011