Lynda Wang - Page 5

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          Graduate School books, research papers & reports & notes, which             
          are for my career & business”.  At trial, petitioner claimed that           
          her 1980 belongings included “my ancient collections of ancient             
          coins and stamps and the picture that I took all over the United            
          States, thousands.  What else?  Also my family memories.  That’s            
          most important.  Once it’s missing, I couldn’t replace them.”               
          Unfortunately, memories are delectable, but memories are not                
          deductible.  Loss of sentimental value is not a deductible loss.            
          Ganas v. Commissioner, T.C. Memo. 1990-143, affd. without                   
          published opinion 943 F.2d 1317 (11th Cir. 1991).                           
               Petitioner did not prove the value of her 1980 belongings.             
          Petitioner did not prove the theft of these belongings.  She did            
          not have a police report.  She claimed she brought a legal action           
          against her landlord but failed to prove that fact or any result            
          from any legal action.                                                      
               Other than bare assertions, petitioner presented no evidence           
          that she sustained a theft loss in 1980.  At trial, petitioner’s            
          statements regarding the alleged theft were inconsistent.                   
          Petitioner presented no evidence to substantiate her entitlement            
          to the alleged 1980 theft loss, which she claimed as a deduction            
          for taxable year 2000.                                                      
               On this record, we conclude that petitioner is not entitled            
          to a theft loss deduction.  Because we so conclude, we need not             
          reach the issue of whether petitioner was entitled to a                     






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