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states a basis for the damaged building of $155,836 and states
that the fair market value of the damaged building before
casualty was $154,000, and after casualty was $0.8 The Form 4684
claims a total casualty loss of $155,836.9
Respondent’s examination in the instant case commenced prior
to July 22, 1998. During the examination, Mr. Finder submitted
the document petitioner had given him to the revenue agent
conducting the examination to support the claimed deduction.
In the notice of deficiency, respondent determined that
petitioner was not entitled to the claimed loss deduction because
he did not (1) establish the decrease in the fair market value of
the Property as a result of the roof collapse, (2) establish his
adjusted basis in the Property, and (3) provide documentation to
support the claimed deduction.
Bad Debt Deduction (Ms. Weinstein)
In addition to leasing buildings to his corporation,
petitioner also leased real property to successive businesses
owned by Rose Weinstein (Ms. Weinstein), a professional tennis
instructor. The businesses operated swim and tennis clubs.
The businesses paid annual rents to petitioner ranging from
8 The record does not reflect how these figures were
generated.
9 Because the building was alleged to have been totally
destroyed, the Form 4684 uses the stated basis as the casualty
loss deduction, even though that amount exceeded the stated value
of the south building of $154,000. See sec. 1.165-7(b)(1)(ii),
Income Tax Regs.
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