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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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