Arlan L. Rower and Sandra M. Howard - Page 7

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          an attachment to their 1993 amended return that the $13,010 loss            
          that they were claiming in that Form 4797 was reported on line              
          15, Other gains or (losses), of their 1993 return, rather than in           
          their 1993 Schedule D, as reported in their original 1993 return.           
               For 1994 and 1995, petitioners reported petitioner's automo-           
          bile repair activity as a partnership and claimed losses from               
          that partnership in the amounts of $13,013 and $6,161, respec-              
          tively.                                                                     
          Petitioners' Claimed Casualty Loss                                          
               During 1994, petitioners received $3,067 from the Federal              
          Emergency Management Agency stemming from a claim due to an                 
          earthquake that occurred during 1994 (Northridge earthquake).  At           
          the time of that earthquake, petitioners were not covered by                
          insurance for earthquake damage.                                            
               During March 1994, petitioners received two estimates of the           
          cost of repairs to their house, one from Steven Berkus Construc-            
          tion for $15,900 (Berkus estimate) and one from Ernesto Laurel              
          (Mr. Laurel) for $16,300 (Laurel estimate).  Each of those                  
          estimates indicated that it was for repairs due to earthquake               
          damage.  During 1994, petitioners purchased $561 worth of sup-              
          plies and hardware, and they paid Mr. Laurel $655.                          
               Although the Northridge earthquake occurred during 1994,               
          pursuant to section 165(i)(1), petitioners claimed a casualty               
          loss deduction of $11,371 in Form 4684, Casualties and Thefts               





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