- 20 - entitled to deduct the claimed Schedule C car and truck expenses at issue. Consequently, we sustain respondent’s determinations disallowing those claimed expenses. Certain Insurance Reimbursements Respondent determined that petitioners must include in income for 1994 and 1995 insurance proceeds in the amounts of $4,300 and $4,700, respectively, that they received as reimburse- ments for certain of Mr. Owens’ business tools which had been stolen in prior years and the cost of which petitioners deducted in returns that they had filed prior to 1994 and 1995. Based on our examination of the entire record before us, we find that petitioners have failed to prove that the insurance reimbursements of $4,300 and $4,700 that they received during 1994 and 1995, respectively, do not constitute income.11 See sec. 1.165-1(d)(2)(iii), Income Tax Regs. Consequently, we sustain respondent’s determinations with respect to those insur- ance reimbursements. Claimed Net Operating Loss Deductions At trial, petitioners took the position that they are entitled to a net operating loss deduction for each of the years at issue, which is attributable to net operating loss carryovers 11We are not persuaded by petitioners’ general, vague, and conclusory testimony regarding their alleged purchase of other tools during 1994 and 1995 that the insurance reimbursements at issue do not constitute income.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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