- 11 - Commissioner, T.C. Memo. 1998-173. In any event, even if a loss were realized on foreclosure, the loss would not be deductible because the Merritt Island property was petitioner’s personal residence. See Quinn v. Commissioner, T.C. Memo. 1983-485; secs. 1.165-9(a), 1.262-1(b)(4), Income Tax Regs. In view of the foregoing, we hold that petitioner is not entitled to any carryover of a casualty or theft loss in respect of the Merritt Island property for the year in issue. Respondent’s determination is therefore sustained. To give effect to the foregoing, Decision will be entered for respondent. 10(...continued) the property prior to the foreclosure. See also supra note 3.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
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