- -8 deficiency respondent determined that petitioners' income for 1991 should be reduced by the $32,040. The parties agree to the reduction in income. Petitioners' receipt of the $32,040 will be considered in computing the casualty loss deduction to which petitioners may be entitled in 1991 caused by the heavy rain and wind which occurred in 1988. Petitioners claimed a deduction of $119,435 on their joint Federal income tax return for the taxable year 1989 as a "casualty carry over from 1988" relating to the $142,729 casualty loss deduction claimed by them on their 1988 return. Respondent sent a notice of deficiency to petitioners for 1989 disallowing the casualty loss carryover deduction. Petitioners filed their petition with this Court seeking a redetermination of their Federal income tax for 1989. The case was settled prior to trial. Pursuant to the settlement, petitioners conceded that they were not entitled to the casualty loss carryover deduction claimed by them for 1989 in exchange for respondent's agreement that the casualty loss deduction in the amount of $142,729 claimed by petitioners on their 1988 return was properly before the Court for the taxable year 1991. Petitioners claimed a miscellaneous deduction in the amount of $81,643 on their joint Federal income tax return for the taxable year 1990 as a "casualty carry over from 1988-1989" relating to the $142,729 casualty loss deduction claimed by petitioners on their 1988 return. In the notice of deficiencyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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