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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.
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Last modified: May 25, 2011