Robert Charles Fohrmeister - Page 7

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          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.                                                                     




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