- 4 - entered into an arrangement where Mr. Tripaldi lent approximately $30,000 to petitioner for the purchase of the home. The loan obligation was to be secured by petitioner’s condominium. No loan documents were created to memorialize the loan. In other words, the parties’ intent was to enter into a secured loan transaction by use of the 50-percent interest quitclaimed to Mr. Tripaldi. As exhibited by the quitclaim deed, dated August 29, 1994, Mr. Tripaldi testified that he relinquished his “security interest” in the condominium when petitioner purportedly satisfied her loan obligation. Petitioner filed and was granted an automatic extension of time to file her 1995 Federal income tax return. Petitioner timely filed her 1995 Federal income tax return, in which she reported a casualty loss of $21,935.49 attributable to damage to the condominium from the 1994 Northridge earthquake. Petitioner attached to her 1995 return a four-page, single-spaced, itemized list of necessary repairs to the condominium (repair list). Petitioner based the repair list, categorized by the estimated cost for damage which occurred in each room, from an itemized list of repairs prepared by State Farm Insurance Co. (State Farm), dated June 20, 1996. Petitioner did not make the repairs or incur any repair expenses for items listed on the repair list during 1995 or any other year. On her 1994 Federal income tax return, petitioner claimed aPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011