- 2 - After concessions, the issues for decision are: (1) Whether Mr. Brown is entitled to a loss deduction in the amount of $30,900 for currency that was seized by Louisiana law enforcement officials pursuant to a civil forfeiture statute; (2) whether Mr. Brown is entitled to a Schedule E loss deduction in the amount of $5,000 for a deposit he made on a townhouse; (3) whether Mr. Brown is entitled to claim a deduction for a theft loss in the amount of $22,300; and (4) whether Mr. Brown is liable for self- employment taxes under the provisions of section 1401. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Mr. Brown resided in Alexandria, Louisiana, at the time the petition was filed. On September 28, 1993, Mr. Brown was arrested along with two other individuals in Lake Charles, Louisiana. At the time of his arrest, Mr. Brown was carrying $30,900 in currency. Law enforcement officials confiscated the currency as suspected drug money. On November 2, 1993, before the State of Louisiana had instituted formal judicial forfeiture proceedings, Mr. Brown 1(...continued) Practice and Procedure. 2On Mar. 18, 1996, respondent filed a report to the Court conceding that Mr. Brown was not liable for the accuracy-related penalty under sec. 6662(a).Page: Previous 1 2 3 4 5 6 7 8 9 Next
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