Steven K. Stoddard and Ellen M. Stoddard - Page 13




                                       - 13 -                                         
               In their 1997 amended joint return, petitioners claimed an             
          amended casualty loss deduction of $168,266 with respect to the             
          Quissett, an increase of $30,010 in the casualty loss deduction             
          that petitioners claimed in Schedule A of their 1997 joint                  
          return.  As required, petitioners filed Form 4684, Casualties and           
          Thefts (amended Form 4684), with the Form 1040X for 1997.  In               
          section A of the amended Form 4684 for 1997, Personal Use Prop-             
          erty, petitioners indicated (1) that the “Cost or other basis” of           
          the Quissett was $186,492, (2) that they had no “Insurance 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 $0, and (6) that the amount of the casualty loss               
          with respect to the Quissett, after applying certain limitations,           
          was $168,266.                                                               
          Notice of Deficiency                                                        
               In the notice issued to petitioners for the years at issue,            
          respondent determined, inter alia, to disallow a casualty loss              
          deduction of $138,256 that petitioners claimed in their 1997                
          joint return with respect to the Quissett.  Respondent further              
          determined to disallow the net operating loss (NOL) carryback               
          deductions of $87,812 and $30,045 that petitioners claimed in               
          their respective amended returns for 1995 and 1996.  Respondent             







Page:  Previous  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  Next

Last modified: May 25, 2011