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rental income of $4,385.20 and claimed rental expense deductions
of $29,382.66, which included $8,806.68 for claimed depreciation,
and a 1996 Schedule E loss of $24,997.46.
The 1997 joint return included Schedule A. In the 1997
Schedule A, petitioners claimed, inter alia, a casualty loss
deduction of $138,256 with respect to the Quissett. As required,
petitioners filed Form 4684, Casualties and Thefts (Form 4684),
with the 1997 joint return. In section A of Form 4684, Personal
Use Property, petitioners indicated (1) that the “Cost or other
basis” of the Quissett was $144,990, (2) that they had no “Insur-
ance or other reimbursement” with respect to the Quissett,
(3) that they had no gain from casualty or theft, (4) that the
fair market value before the casualty or theft of the Quissett
was $175,000, (5) that the fair market value of the Quissett
after the casualty or theft was $22,000, and (6) that the amount
of the casualty loss with respect to the Quissett, after applying
certain limitations, was $138,256.
The 1997 joint return also included Schedule E. With
respect to the Doon Way residence, the 1997 Schedule E reported
no rents received and claimed rental expense deductions of
$17,438, consisting of $391 for claimed advertising, $834 for
claimed cleaning and maintenance, $375 for claimed insurance,
$1,200 for claimed utilities, and $14,638 for claimed deprecia-
tion, and a 1997 Schedule E loss of $17,438.
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Last modified: May 25, 2011