Ilija and Branka Mitic - Page 9




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            (2) that the “Insurance or other reimbursement” with respect to                            
            that automobile was $27,000, (3) that they had no gain from a                              
            casualty or theft, (4) that the fair market value before the                               
            casualty or theft of Mr. Mitic’s Mercedes was $55,000, (5) that                            
            the fair market value of that automobile after the casualty or                             
            theft was zero, and (6) that the amount of the casualty loss with                          
            respect to Mr. Mitic’s Mercedes was $40,500.  The amount of                                
            $27,000 that petitioners indicated in Form 4684 was the “Insur-                            
            ance or other reimbursement” with respect to that vehicle repre-                           
            sented petitioners’ estimate of the amount to be paid by State                             
            Farm in settlement of the automobile damage claim.                                         
                  In the 1994 joint return, petitioners claimed a depreciation                         
            deduction for the entire year with respect to the Geo that they                            
            had purchased from their son in December 1994.  Petitioners also                           
            claimed in the 1994 joint return depreciation deductions with                              
            respect to the Toyota and another automobile.                                              
            Notice of Deficiency                                                                       
                  In the notice of deficiency (notice) issued to petitioners                           
            for the years at issue, respondent, inter alia, disallowed:                                
            (1) For 1993 the entire medical expense deduction, except for                              
            $3,889 for physicians and medicines, that petitioners claimed in                           
            the 1993 joint return (petitioners’ claimed medical expense                                
            deduction at issue) and (2) for 1994 (a) the casualty loss                                 
            deduction with respect to Mr. Mitic’s Mercedes and (b) the                                 






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