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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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Last modified: May 25, 2011