- 13 - exceed adjusted basis. Lamphere v. Commissioner, 70 T.C. 391, 395 (1978). Ordinarily an appraisal is required. Sec. 1.165- 7(a)(2)(i), Income Tax Regs. The regulations also permit the cost of repairs as evidence of the amount of the loss. Sec. 1.165-7(a)(2)(ii), Income Tax Regs. However, this must be the cost of repairs actually made, not the estimated cost of repairs. Lamphere v. Commissioner, supra at 396. Petitioner has introduced no appraisal and no evidence of repairs actually made. Thus, she is not entitled to the deduction. Bad Debt Petitioner claims a bad debt deduction in the amount of $750. Respondent argues that petitioner has not proved that the debts were worthless and that petitioner did not include the $750 in income. Petitioner taught some students in a nursing review course, and they did not pay her the $750 they had agreed on. Petitioner did not include the $750 in income. Section 166(a)(1) permits a deduction for debts that become worthless in the year in issue. Petitioner has provided no evidence that the debts became worthless during the year in issue. See sec. 1.166-2, Income Tax Regs. Moreover, to be entitled to a bad debt deduction, petitioner must have included the $750 in income either in 1993 or in some previous year. Sec. 1.166-1(e), Income Tax Regs. She did not, and therefore she is not entitled to the deduction.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011