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record is stamped received by respondent on December 7, 1998.
Respondent’s records do not reflect a 1995 tax return filed prior
to that date. On her 1995 Federal income tax return, petitioner
claimed a casualty loss deduction in the amount of $47,472, which
was a carryover from the 1994 return. Petitioner filed her 1998
Federal income tax return on January 3, 2000. Petitioner had
requested and been granted an extension to file until August 15,
1999. There is no record of any further request or granting of
an extension. Attached to the Federal income tax return is Form
4684, Casualty and Thefts. On her 1998 return, petitioner
reported a total casualty and theft loss of $138,479 and claimed
a loss deduction of $130,851. On the Form 4684, petitioner
calculated the casualty loss as follows:
Real Personal
Property Property
Cost $100,000 $216,330
Insurance
reimbursement 10,000 –--
Fair market value
before casualty 142,000 112,059
Fair market value
after casualty 100,000 5,580
$42,000 $106,479
Less insurance (10,000) ---
$32,000 $106,479
Total $138,479
Less $100 (100)
Less 10% of adjusted gross income 7,528
Claimed loss deduction $130,851
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