Chester J. Janas - Page 3

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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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