Juanita Carter - Page 16

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          Deductions, to which amount petitioner added $250 for "Theft" and           
          $400 for a bad debt, all of which totaled $5,039 as a casualty              
          loss claim.  Petitioner contends that she sustained the casualty            
          during 1989 as a result of an eminent domain action against her             
          Lurch Street home in connection with the expansion of the St.               
          Louis Municipal Airport (airport).  Pursuant to such eminent                
          domain procedures, petitioner sold her house to the City of St.             
          Louis, Missouri, during 1989 and secured alternate housing.                 
          Petitioner contends that, at some time during 1989, the airport             
          arranged for the moving of petitioner's personal belongings from            
          her old home into her new home; however, some items of her                  
          personal property were left behind in the basement of her former            
          home, and, before petitioner had the opportunity to retrieve her            
          personal property, the airport demolished the home, including her           
          personal property.                                                          
               On August 23, 1993, petitioner filed a Complaint in the U.S.           
          District Court for the Eastern District of Missouri (District               
          Court) against the airport requesting, among other relief,                  
          reimbursement for her damaged personal property.  On October 27,            
          1995, the District Court dismissed petitioner's Complaint, with             
          prejudice.                                                                  
               Petitioner contends that she should be allowed to deduct the           
          full amount of her loss in 1989 as a casualty loss because she              







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