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Petitioner used the deduction to offset previously reported
taxable income in the amount of $10,703.
On his 1996 Form 1040, U.S. Individual Income Tax Return,
petitioner claimed a carryover loss in the amount of $59,287 in
respect of the Merritt Island property.6 Petitioner used the
carryover to completely offset his reported income for that year.
On his 1997 income tax return, Form 1040, petitioner claimed
a carryover loss in the amount of $29,947 in respect of the
Merritt Island property. Petitioner used the carryover to
completely offset his reported income for that year.
On his 1998 income tax return, Form 1040, petitioner claimed
a carryover loss in the amount of $25,811.21 in respect of the
Merritt Island property. Petitioner used the carryover to
completely offset his reported income for that year.
E. The Notice of Deficiency
Respondent determined a deficiency in petitioner’s income
tax for 1998. The deficiency is attributable solely to the
disallowance of the $25,811.21 carryover loss claimed by
5(...continued)
1040X. It would appear that the amount of the claimed loss
represented petitioner’s estimate of the then fair market value
of the Merritt Island property.
6 This amount represents the difference between $70,000,
the amount of the casualty or theft loss claimed on the Form
1040X for 1995, and $10,703, petitioner’s taxable income for that
year. Arithmetically, the difference between these two amounts
is $59,297. The amount claimed by petitioner on his 1996 return,
$59,287, reflects a $10 computational or typographical error.
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