- 15 - 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 (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011