- 3 -
unfortunately, did not cover flooding. Petitioner did not
attempt to file any claim with her insurance carrier.
Petitioner timely filed a Federal income tax return for the
2001 taxable year. On her Form 1040, U.S. Individual Income Tax
Return, petitioner claimed a casualty loss deduction of $19,068,
after application of the $100 limitation, pursuant to section
165(h)(1), and the 10 percent of adjusted gross income
limitation, pursuant to section 165(h)(2). Petitioner attached
to the Form 1040 a Schedule A, Itemized Deductions, and a Form
4684, Casualties and Thefts, along with schedules that were meant
to verify such casualty calculations.
On Form 4684, petitioner described the property for which
she claimed a casualty loss as: “Clothing acquired 01-01-01,
appliances, tools, and electronics”. The Form 4684 reflected in
pertinent part as follows:
Section A--Personal Use Property
Property Description Clothing acquired 01-01-01
Line A2. Cost or other basis of each property$9,200
Line A3. Insurance or other reimbursement 0
Line A5. Fair market value before casualty or theft 8,900
Line A6. Fair market value after casualty or theft0
Line A7. Subtract line 6 from line 5 8,900
Line A8. Enter the smaller of line 2 or line 78,900
Line A9. Subtract line 3 from line 8 8,900
Property Description Appliances
Line A2. Cost or other basis of each property$5,850
Line A3. Insurance or other reimbursement 0
Line A5. Fair market value before casualty or theft 4,950
Line A6. Fair market value after casualty or theft0
Line A7. Subtract line 6 from line 5 4,950
Line A8. Enter the smaller of line 2 or line 74,950
Line A9. Subtract line 3 from line 8 4,950
Property Description Tools
Line A2. Cost or other basis of each property$1,500
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011