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whom petitioner maintained a homeowner’s insurance policy during
1998. On October 12, 1998, State Farm settled the claim with
petitioner for $857.12. On October 29, 1998, petitioner retained
a contractor to replace rotten decking and install a new roof on
petitioner’s house. For the year at issue, petitioner claimed a
casualty loss deduction on Schedule A, Itemized Deductions, of
$5,151.19 related to the damage caused by the storm.
In the notice of deficiency, respondent disallowed the
following: (1) The entire section 179 expense deduction claimed
on Schedule C because petitioner “did not establish the
percentage of business use” for the van and failed to provide
other supporting information required to substantiate the
deduction; (2) the business-related travel expense for the van
claimed on Schedule C because petitioner failed to provide the
supporting information necessary to establish that the deduction
was “(a) incurred during the taxable year, and (b) an ordinary
and necessary business expense”; (3) expenses claimed on Schedule
C for (a) production and management fees, and (b) music educator
and professional convention expenses because petitioner did not
substantiate that these expenses were paid or incurred during the
taxable year and were “ordinary and necessary” business expenses;
and (4) the entire casualty loss deduction claimed on Schedule A
because petitioner “did not establish that (a) a casualty or
theft occurred, and (b) any loss was sustained”.
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Last modified: May 25, 2011