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been satisified under Florida law for the Police Department to
remain in possession of those items and to continue the
forfeiture proceeding. See Fla. Stat. Ann. sec. 932.703(1) (West
1985). A final order of forfeiture was never entered in this
case because petitioner, through his attorney, negotiated an
agreement with the police enabling him to repurchase his property
for a price of $90,900. After he repurchased the property,
petitioner and the Police Department settled and dismissed the
matter.
On November 4, 1992, petitioner filed his 1987 Federal
income tax return. On his Schedule A, Itemized Deductions,
petitioner claimed a charitable contribution deduction with
respect to the amounts he paid to the Police Department.1
Petitioner also claimed a $161,100 casualty loss for the items of
personal property seized by the police. Petitioner also claimed,
a bad debt deduction of $176,500, which was based on alleged
loans to two individuals, Ashley Dunn (Mr. Dunn) and William
Crowl (Mr. Crowl).
OPINION
1 Petitioner originally reported that he transferred
$152,297 of Chrysler Corp. stock to the Police Department, as a
charitable contribution. Petitioner, however, never transferred
any shares of Chrysler Corp. stock to the Police Department.
Instead, the Chrysler Corp. stock was sold, and the proceeds were
used to repurchase petitioner's personal property from the Police
Department for $90,900.
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