-2- After concessions, the following issues remain for our consideration: (1) Whether petitioners are entitled to a casualty loss deduction in the amount of $220,000 for the 1992 taxable year, and (2) whether any underpayment of tax is due to either negligence or intentional disregard of rules or regulations. FINDINGS OF FACT2 Petitioners Imre and Gizella Cziraki are husband and wife and resided in Huntington Beach, California, at the time of the filing of their petition. In 1975, petitioners purchased two parcels of property covering 80 acres in the county of San Diego for $70,000. For simplicity, hereinafter the 80 acres of property shall be referred to as “property A”. In 1983, petitioners purchased 38 acres adjacent to property A for $150,000. Hereinafter, the 38 acres of property shall be referred to as “property B”. Petitioners utilized properties A and B for their wholly owned farming business, the Rainbow Hills Nursery. The Rainbow Hills Nursery grows protea flowers, macadamia trees, aloe vera plants, and palm trees for sale. At the time petitioners purchased property A, there existed a road, partially of asphalt, that traversed a portion of property A, but which did not 2 The stipulation of facts and the attached exhibits are incorporated by this reference.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011