- 15 - 8. Notice of Deficiency On September 18, 1995,6 respondent mailed a notice of deficiency to petitioner determining deficiencies for her 1988, 1989, and 1991 tax years. The notice of deficiency disallowed the 1991 section 165(l) deduction and resultant net operating loss carrybacks. OPINION Issue 1. Loss Arising From Qualified Financial Institution Petitioner, along with her deceased husband, lost funds on deposit in the infamous BCCI fiasco and claimed a casualty loss under section 165(c)(3). The gist of this case is whether BCCI, S.A. is a "qualified financial institution" within the meaning of section 165(l)(3). Section 165(l) provides special treatment to certain losses caused by deposits in insolvent financial institutions. See Fincher v. Commissioner, 105 T.C. 126 (1995). If its statutory prerequisites are met, section 165(l) permits individuals to treat a loss on a deposit as a casualty loss in the year the loss amount 6 On Oct. 5, 1995, respondent mailed a duplicate notice of deficiency to petitioner for tax years 1988, 1989, and 1991. The second notice of deficiency corrected a typographical error in the date of the original notice of deficiency (erroneously dated Sept. 18, 1996). Apart from the dates, the two notices are identical.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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