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requests and remittances of $11,000 and $3,900 for 1993 and 1994,
respectively. Because petitioner failed to file his Federal
income tax returns, respondent created substitute returns from
the Forms 1099 that petitioner's payors had submitted. These
substitute returns formed the basis of respondent's notice of
deficiency.
In the notice of deficiency, respondent determined that in
1993 petitioner received $58,672 from Medical Doctor Associates,
Inc., and in 1994 petitioner received $11,877 from Medical Doctor
Associates, Inc., plus Schedule C gross receipts of $48,046.
Respondent now concedes that the $48,046 Schedule C adjustment is
erroneous but asserts, in an amended answer, that petitioner's
1994 income should be increased by $8,000 that petitioner
allegedly received from Gibson General Hospital. Petitioner does
not contest the additional $8,000, and he concedes the remaining
items of income determined in the notice of deficiency.
Petitioner asserts, however, that his taxable income should be
reduced for casualty losses he sustained during each of the years
in issue.
Section 165 allows a deduction for casualty losses sustained
during the taxable year and not compensated for by insurance.
Petitioner contends that he owned property located in Danville,
Illinois, and that in 1993 such property was destroyed by a fire,
resulting in an alleged $164,123 loss. Petitioner has failed,
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