Douglas L. Hadsell - Page 16




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          at issue.  At trial on January 30, 1998, petitioner failed to                  
          adduce any additional evidence substantiating his claimed                      
          deductions.  Therefore, we do not change our previous finding                  
          that we have no basis to allow petitioner to claim either rental               
          real property expenses or casualty losses for the years at issue.              
          Respondent is sustained on this issue.                                         
          4.  Casualty Losses for a Boat and Personal Property That Were                 
          Destroyed                                                                      
               At trial in Hadsell I, petitioner testified concerning a                  
          boat he purchased in either 1986 or 1987 which was later                       
          destroyed.  Petitioner also testified that he incurred a casualty              
          loss for personal property stored on the boat when it was                      
          destroyed.  Petitioner concedes that the boat at issue, and any                
          personal property stored aboard, was destroyed in 1992.  Since                 
          petitioner’s loss did not occur during the years at issue, any                 
          casualty loss deduction to which petitioner might be entitled                  
          with respect to either the boat or personal property stored on                 
          the boat when it was destroyed would not be allowable in any of                
          the years at issue in this case.                                               
          5.  Additions to Tax for Failure To File a Timely Return                       
               Section 6651(a)(1) imposes an addition to tax for failure to              
          file a timely tax return.  The addition to tax is equal to 5                   
          percent of the amount of the tax required to be shown on the                   
          return if the failure to file is not for more than 1 month.  See               





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