Elliot Virgil Wilkerson - Page 6

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          on Form 4684.  Petitioner attached no documentation to his                  
          revised Form 1040 to support any of the itemized deductions.                
               On Form 4684, petitioner described the property for which he           
          claimed a casualty or theft loss as:  “Personal, Cedar Springs,             
          Ga, 04/22/47”.  The personal property referred to certain                   
          employment rights that petitioner allegedly forfeited in a                  
          collective bargaining agreement that his labor union entered into           
          sometime before 1997.  “Cedar Springs, Ga” is the location of               
          GNNC, which is the paper mill where petitioner works.  The date             
          “04/22/47” is petitioner’s birth date.  The Form 4684 reflected             
          in pertinent part as follows:                                               
               Line 2.  Cost or other basis of each property   $10,900                
               Line 5.  Fair market value before casualty or theft43,600                 
               Line 6.  Fair market value after casualty or theft10,900                 
               Line 7.  Subtract line 6 from line 5            32,700                 
               Line 10.  Casualty or theft loss. * * *         10,900                 
               Line 11.  Enter the amount from line 10 or $100,                       
               whichever is smaller                            100                    
               Line 17.  Enter 10% of your adjusted gross income * * *   3,517        
               Line 18. * * * enter result on Schedule A * * * 7,283                  
               On Schedule C, petitioner identified his business name as              
          V.G.’s Gallery, his principal business or profession as art and             
          flowers, and his business activity code as 453220, signifying a             
          gift, novelty, and souvenir store.  Schedule C reflected in                 
          relevant part as follows:                                                   
               Gross receipts or sales       $1,891                                   
               Returns or allowances         899                                      
               Cost of goods sold            903                                      
               Gross income                  89                                       
               Total expenses                4,296                                    
               Net loss                      (4,207)                                  






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