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Avenue property for 1987. The remaining mortgage interest
deductions for 1987 is not conceded, and petitioner has provided
no evidence or argument to show entitlement to mortgage interest
deductions in excess of those allowed or conceded by respondent.
Accordingly, petitioner is not entitled to mortgage interest
deductions in excess of those allowed by respondent.
B. Casualty Losses
Petitioner claimed casualty losses attributable to theft of
$21,000 and $31,860 for 1987 and 1991, respectively. Section
165(a) permits a deduction for losses not compensated for by
insurance or otherwise. The loss for a casualty, however, is
subject to limitations. The loss may be allowable for 1987 to
the extent that it exceeds $100. Sec. 165(h)(1). In addition,
the loss is deductible only to the extent that it also exceeds 10
percent of a taxpayer’s adjusted gross income. Sec. 165(h)(2).
Applying those rules to petitioner’s $21,000 claimed
casualty loss for 1987, the amount would not exceed the statutory
thresholds or limitations. First, the claim is limited to
$20,900 ($21,000, less the $100 threshold). Second, because
petitioner’s adjusted gross income was approximately $495,000,
the 10-percent limitation would preclude any deduction for a
casualty loss of less than $49,500. Accordingly, petitioner is
not entitled to an itemized casualty loss deduction for 1987.
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