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following represents our conclusion as to the amount of
petitioner’s loss:
Fair Market Value Before
the Casualty or Other
Item Cost Related to Casualty
Personal item including
clothing
17,500
Furniture 20,000
Miscellaneous 3,000
Carpet 5,500
Total $46,000
Fair market value
before casualty $46,000
Fair market value
after casualty
5,580
Balance $40,420
Less insurance (12,500)
Casualty Loss $27,920
We conclude that petitioner is entitled to a casualty loss
in the amount of $27,920, as computed above, prior to any
statutory reductions. Sec. 165(h).
Additions to Tax Under Section 6651(a)(1)
Section 6651(a)(1) imposes an addition to tax of 5 percent
per month of the amount of tax required to be shown on the
return, not to exceed 25 percent, for failure to timely file a
return. The addition to tax under section 6651(a)(1) is imposed
unless the taxpayer establishes that the failure was due to
reasonable cause and not willful neglect.7 The record does not
7 Sec. 7491(c) provides that the Commissioner has the
burden of production in any Court proceeding with respect to
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