Tracy M. Colter and Robert N. Colter, Jr. - Page 12




                                       - 11 -                                         
          and find that petitioners are entitled to a casualty loss                   
          deduction for 1995 computed as follows:                                     
               Fair market value of personal property                                 
               listed on inventory, plus fair market                                  
               value of personal property not listed                                  
               on inventory, (values before fire)           $56,273.17                
               Fair market value of personal property                                 
               after fire                                   - 0 -                     
               Less insurance reimbursement                 45,732.06                 
          Less $100 (sec. 165(h)(1))                        100.00                    
               Less 10% of AGI (sec. 165(h)(2))             4,280.00                  
               Allowable casualty loss deduction       6,161.11                       

               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               Based on the foregoing,                                                
                                                  Decision will be                    
                                             entered under Rule 155.                  

























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