Jane B. Oliver and Robert P. Oliver - Page 8

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          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 deficiency              




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