Imre and Gizella Cziraki - Page 2

                                         -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.                                             




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