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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 events
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