- 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. RespondentPage: 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