Jane B. Oliver and Robert P. Oliver - Page 2

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          Additions to Tax and Accuracy-Related Penalties                             
          Year   Deficiency       Sec. 6651(a)(1)    Sec. 6662                        
          1990    $29,155     $7,988            $5,831                                
          1991     55,873     11,730            11,175                                
               Some of the issues were conceded or settled by the parties.            
          The issues presented for decision are:  (1) Whether petitioners             
          are entitled to casualty loss deductions for the taxable year               
          1991 caused by heavy rain and wind damage to their home and                 
          personal property which occurred in 1988 and for flooding which             
          occurred in 1991 and, if so, the amounts of the losses sustained;           
          (2) whether petitioners are entitled to a casualty loss carryover           
          deduction for the taxable year 1990 caused by the heavy rain and            
          wind damage which occurred in 1988; (3) whether petitioners are             
          entitled to a business casualty loss deduction for computer and             
          computer-related equipment for the taxable year 1991 caused by              
          the flooding which occurred in that year; (4) whether petitioners           
          are entitled to a casualty loss deduction for the taxable year              
          1991 for damage caused by broken water pipes in their kitchen;              
          (5) whether petitioners are entitled to relief under section                
          165(i)1 with respect to casualty losses suffered by them during             
          the taxable year 1991; (6) whether petitioners failed to report a           
          casualty gain for the taxable year 1991 arising from flooding in            


          1  All section references are to the Internal Revenue Code in               
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure, unless otherwise                 
          indicated.                                                                  




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