Narvell Darling - Page 6

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          that petitioner has failed to produce any credible evidence to              
          substantiate his claimed loss, including the occurrence of any              
          casualty, or, if a casualty occurred, the amount deductible.                
               Section 165(a)1 allows as a deduction any loss sustained               
          during the taxable year and not compensated for by insurance or             
          otherwise.  Section 165(c) limits the allowance of losses in the            
          cases of individuals.  Section 165(c)(3) allows as a deduction to           
          an individual certain losses commonly referred to as casualty               
          losses.  A casualty loss is allowable to an individual for a loss           
          of property not connected with a trade or business or with a                
          transaction entered into for profit, if the loss results from               


          1Sec. 165.  Losses.                                                         
                    (a) General rule.--There shall be allowed as a                    
               deduction any loss sustained during the taxable year and not           
               compensated for by insurance or otherwise.                             
                         *    *    *    *    *    *    *                              
                    (c) Limitation on losses of individuals.--In the case             
               of an individual, the deduction under subsection (a) shall             
               be limited to–-                                                        
                         (1) losses incurred in a trade or business;                  
                         (2) losses incurred in any transaction entered               
                    into for profit, though not connected with a trade or             
                    business; and                                                     
                         (3) except as provided in subsection (h), losses             
                    of property not connected with a trade or business or a           
                    transaction entered into for profit, if such losses               
                    arise from fire, storm, shipwreck, or other casualty,             
          or from theft.                                                              






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