- 8 -
purchased the land using proceeds it received pursuant to a
judgment by the Indian Claims Commission in Docket No. 75 that
were distributed pursuant to the Act of September 27, 1967, Pub.
L. 90-93, 81 Stat. 229, 25 U.S.C. secs. 1141-1147 (2000).
Petitioners did not report the two payments (totaling
$3,000) on their 1999 return. Respondent determined that the
payments were taxable per capita payments in that year.
Charitable Contributions
Petitioners claimed deductions for charitable contributions
on their 1997 and 2000 returns of $5,899 and $3,969,
respectively. The notice of deficiency disallowed these
deductions for failure to substantiate.
Casualty Loss
Petitioners claimed a casualty loss of $4,516 on their 2000
return.
In April 2000, a water main adjacent to petitioners'
residence broke and their basement was flooded with 4 to 5 feet
of water. Petitioners' loss was not covered by insurance. The
notice of deficiency disallowed the claimed $4,516 casualty loss.
Accuracy-Related Penalties
Petitioners previously appeared before this Court for
redetermination of a deficiency with respect to their 1991
5(...continued)
742 n.1 (9th Cir. 1971), affg. in part and revg. in part 52 T.C.
330 (1969).
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011