Jane B. Oliver and Robert P. Oliver - Page 31

                                         31-  -                                        
          year 1988.  Thus, their claimed cost basis ($23,700) in this                
          computer equipment should have been reduced by the claimed                  
          depreciation and section 179 expense by $2,740, which results in            
          a $20,960 adjusted basis.  Sec. 1016(a)(2)(A).                              
               Even if petitioners had included the proper adjusted basis             
          of their computer equipment in their $58,202.28 total claimed               
          cost basis, however, they have failed to prove that they were               
          entitled to calculate their claimed casualty loss based on the              
          original cost of the contents of their home, rather than using              
          the decrease in the fair market value of the contents of the                
          residence as the appropriate measure of their sustained casualty            
          loss.                                                                       
               We are not persuaded by petitioners' evidence that the loss            
          to the contents of their home is $58,202.28 as a result of the              
          February flood.  The total amount of the invoices submitted by              
          them does not approach $58,202.28.                                          
              Petitioners also presented no evidence that the amount they            
          claim as the cost to repair the contents of their home is not               
          greater than necessary to restore the contents to their condition           
          prior to casualty.  Such evidence is required by section 1.165-             
          7(a)(2)(ii), Income Tax Regs.                                               
               We have found it difficult to determine with reasonable                
          accuracy the amount of the loss sustained by petitioners in the             
          February flood.  Again, petitioners contend that we should                  
          approximate the loss sustained by them as a result of the                   




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