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employee expenses in 1999. We therefore sustain respondent’s
determination on this issue.
c. Casualty and Theft Loss
Petitioner claimed a deduction for a casualty and theft loss
of $6,800 for the 1999 taxable year. He contends that this loss
was attributable to a “computer display, camera, books and side
tables that [he] lost at the storage in Louisville, Kentucky, and
the basement of a family friend.” Petitioner further contends
that he did not recover from any insurance claims.
In general, a taxpayer is entitled to deduct any loss
sustained during the taxable year and not compensated for by
insurance or otherwise. Sec. 165(a). Where the loss is not
connected with a trade or business or a transaction entered into
for profit, the deduction is limited to losses arising “from
fire, storm, shipwreck, or other casualty, or from theft” and the
requirements of section 165(h). Sec. 165(c)(3). Petitioner,
however, has not substantiated either the existence or the amount
of any casualty or theft loss in 1999. We therefore sustain
respondent’s determination on this issue.
5. Accuracy-Related Penalties Under Section 6662(a)
The Commissioner has the “burden of production in any court
proceeding with respect to the liability of any individual for
any penalty” under section 6662(a). Sec. 7491(c); Higbee v.
Commissioner, 116 T.C. 438, 446-447 (2001). Section 6662(a)
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