- 38 - that his loss from this entity in 1992 was only $7,083, which is the same amount of loss that respondent determined in the notice of deficiency. We agree with respondent that all these adjustments and concessions should be taken into account. When that is done, it is clear that there are no losses in 1990 and 1992 that are available to be carried forward to 1993 pursuant to section 172. V. Issue 5. Casualty Loss A. Background On October 2, 1991, petitioner’s son Brian Tietig, who was 17 years old at the time, discovered that a theft and extensive vandalism had occurred at the Miami property. Brian Tietig called the Metro-Dade Police Department and reported the crime on that date. Petitioner completed a property loss report for the Metro-Dade Police Department on January 20, 1992. Petitioner gave what he considered the “replacement costs” of the property stolen from his house in the property loss report he signed on January 20, 1992. Petitioner brought a lawsuit against TransAmerica Premier Insurance Co. (TransAmerica) in 1992 in the Circuit Court for Brevard County, Florida. Petitioner recovered $1,500 from TransAmerica. Petitioner and TransAmerica executed a Property Damage Release on October 4, 1993. After October 4, 1993,Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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