- 46 -
F.2d 559, 560 (5th Cir. 1957); Vanicek v. Commissioner, 85 T.C.
731, 742-743 (1985).
We hold that petitioners did not sustain deductible casualty
losses to the Atmore residence from the 1997 earthquakes or
Hurricane Georges or to the beach lot from Hurricane Georges.
Conclusions
Petitioners are liable for the section 6654(a) addition to
tax in the section 6330 cases, the section 6651(a)(2) addition to
tax in the section 6330 cases for the period April 16 through
October 15, 1998, and the period November 17, 1998, to the date
of payment up to the maximum statutory amount, and the section
6651(a)(1) addition to tax in the section 6330 cases and the
deficiency case for the period November 17 through December 21,
1998. Respondent’s collection determination is sustained.
Petitioners are not entitled to any abatement of interest
with respect to amounts reported on their 1997 return.
Petitioners are not entitled to deduct casualty losses on
their 1997 return because the allowable losses they sustained did
not reach the deduction threshold provided by section 165(h).
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