- 6 - Cost or other basis of each property $139,647 Insurance or other reimbursement 107,022 Fair market value before casualty 133,012 Fair market value after casualty - 0 - Amount of loss 133,012 Amount of loss not reimbursed 25,990 Less $100 floor 100 Less 10 percent of adjusted gross income 4,280 Casualty loss claimed 21,610 In the notice of deficiency, respondent disallowed, at least mathematically, $20,011.04 of the casualty loss deduction here in dispute. A fair reading of the explanation for this adjustment suggests that respondent intended to disallow the entire amount. Nevertheless, we proceed as though petitioners are entitled to a casualty loss deduction of at least $1,598.96 for 1995. In the notice of deficiency respondent also determined that petitioners are liable for a section 6662(a) penalty, but respondent now agrees that they are not. Discussion Subject to certain limitations, an individual is entitled to a deduction for “any loss[es] sustained during the taxable year and not compensated for by insurance or otherwise” that “arise from fire * * * or other casualty”. Sec. 165(a), (c)(3), (h)(1) and (2). To properly compute a casualty loss deduction, the following values of the damaged or destroyed property must be established: (1) Fair market value before the casualty; (2) fair market value after the casualty; and (3) the taxpayer’s basis in the property.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011