- 7 - As petitioner has offered no other evidence with respect to this issue, we sustain respondent's determination. 3. Casualty Loss In 1991, petitioner moved from New Jersey to Clearwater, Florida and contracted with East Bergen Moving Co. (East Bergen) to move his personal belongings. A dispute arose between petitioner and East Bergen concerning the amount charged for the move. Petitioner contended that East Bergen had quoted a price of $550, while East Bergen charged petitioner $1,498.89. Petitioner refused to pay the bill, and East Bergen stored the property in Florida with A Atlantic Coast Moving & Storage Co. (A Atlantic), where it had remained up to the date of trial. Petitioner admitted that there was a possibility that he may recover his property. On his 1991 return, petitioner claimed a casualty loss in the amount of $6,500.6 In his pretrial memorandum, petitioner also refers to the loss as a "theft". Other than the amounts indicated on petitioner's return, there is no evidence in the record concerning his cost basis in the property or its fair market value. Section 165 provides that individual taxpayers may deduct certain losses, including losses resulting from casualty or theft, sustained during the taxable year and not compensated by 6 Although petitioner reported a casualty loss in the amount of $6,500 on his return, his concession regarding Schedule C income has reduced the amount in dispute to $6,490. See supra note 2.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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