Imre and Gizella Cziraki - Page 10

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          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.                          






















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