-10- In sustaining respondent's determination regarding the casualty loss, this case turned on the somewhat technical concept that the road constituted a separate, identifiable piece of property, rather than a part of the real property that surrounds it, for purposes of section 1.165-7(b)(2)(i), Income Tax Regs. Although we have not ruled in favor of petitioners on this issue, their failure to comply with the regulations was due to their reasonable belief that their cost could be allocated to the damage to the road. Consequently, petitioners are not liable for an accuracy-related penalty with respect to the claimed casualty loss. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011