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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,
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