Jane B. Oliver and Robert P. Oliver - Page 39

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          $27,372.91 and $11,687, respectively.  But, in addition,                    
          petitioners received two checks, one for the damage to their                
          home, and one for the damage to its contents, in undisclosed                
          amounts and from an undisclosed insurance company, as                       
          reimbursement for the damage caused by the April flood.                     
               Accordingly, based on the evidence contained in this record,           
          we conclude that petitioners failed to prove that the damage to             
          their home and personal property exceeded the amount of insurance           
          reimbursement they received from ABIC as a result of the April              
          flood.  Petitioners therefore are not entitled to deduct a                  
          casualty loss on their 1991 return for damage caused by that                
          flood.                                                                      
               5.  Claimed Business Casualty Loss Deduction for Computers             
          and Equipment                                                               
               Petitioners deducted a business casualty loss of $6,880 on             
          Schedule C of their 1991 return for damage to computer equipment            
          located at their home at the time of the 1991 floods.  The                  
          equipment consisted of one computer, one hard disk drive, one               
          printer, and software.                                                      
               Respondent contends that the business casualty loss claimed            
          by petitioners for damage to computer equipment was duplicated in           
          the casualty loss deduction arising from the February flood.  We            
          agree, and thus sustain respondent's determination that                     
          petitioners are not entitled to a business casualty loss                    
          deduction for the computers and equipment in 1991.                          





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