- 7 - and 1991, as well as fraud penalties under section 6663 for those same 3 years. In the notice of deficiency, respondent also allowed in part and disallowed in part petitioner’s claim for refund for 1989 (made pursuant to petitioner’s amended return for that year). Thus, respondent allowed petitioner a deduction for a casualty loss for 1989 in the amount of $55 (after taking into account the $100 limitation of section 165(h)(1) and the 10-percent limitation of section 165(h)(2)(A)). In computing the deficiency for 1989, respondent did not take this deduction into account because the deduction, together with petitioner’s other itemized deductions, was less than the standard deduction to which petitioner was otherwise entitled. See sec. 63(c). F. Petitioner’s Testimony at Trial At trial, petitioner testified that he was divorced in 1989; that after his divorce he relocated to another residence and another law office; that he rented a private garage in order to store excess belongings; and that he subsequently discovered that some of his belongings (namely, a washing machine, a lawnmower, and a lawnseeder) had been removed from the garage and that his remaining belongings (namely, books, notes and awards, law library, office furniture and equipment, and “professional research”) had sustained water damage. In addition, petitioner testified that he filed a police report; that he commenced anPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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