-12- exchange for $1,500,000. On August 20, 2003, respondent issued to petitioner a notice of deficiency (notice) with respect to petitioner’s taxable year 2000. In that notice, respondent determined, inter alia, that petitioner is liable for the taxable year at issue for the respective additions to tax under sections 6651(a)(1) and 6654(a). On October 26, 2004, respondent received Form 1040, U.S. Individual Income Tax Return, with respect to petitioner’s taxable year 2000 (petitioner’s Form 1040 for 2000), which respondent did not process as a return. In that form, peti- tioner, inter alia, claimed a $256,975 deduction under section 165 for a theft loss with respect to the custom house. On November 1, 2004, a jury awarded petitioner and Ms. Davis $524,727 in compensatory damages (insurance litigation verdict) with respect to the insurance litigation counterclaim. The jury found, inter alia, that the property damages that petitioner and Ms. Davis sustained were not fully satisfied by the $1,500,000 paid to them pursuant to the May 1, 2003 settlement agreement. As of the time of the trial in this case, the Maryland Circuit Court was considering in the insurance litigation numerous posttrial motions and had not reduced the insurance litigation verdict to final judgment.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011