- 14 - Williams v. United States, supra; Vanicek v. Commissioner, 85 T.C. 731 (1985). C. Personal Deductions 1. Deductions for State and Local Taxes As relevant herein, section 164(a) provides for the deduction of (1) State and local real property taxes; (2) State and local personal property taxes; and (3) State and local income taxes paid or accrued within the taxable year. Petitioner failed to produce any evidence to show that he paid the taxes claimed on his revised Form 1040, nor did he offer any testimony concerning those deductions. Therefore, petitioner has not met his burden of proof. Accordingly, petitioner is not entitled to claim deductions on Schedule A for taxes paid. 2. Casualty Loss Deduction As relevant to the present case, section 165(a) and (c)(3), subject to limitations, allows an individual to claim a deduction for a loss of property not connected with a trade or business that arises “from fire, storm, shipwreck, or other casualty, or from theft”. Personal casualty losses are deductible in the year the loss is sustained. Sec. 165(a), (h)(3)(B); sec. 1.165- 7(a)(1), Income Tax Regs. A loss is “treated as sustained during the taxable year in which the loss occurs as evidenced by closed and completed transactions and as fixed by identifiable eventsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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