George B.N. Ayittey - Page 3

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               Respondent determined a deficiency of $16,319 and a penalty            
          under section 6662 of $2,272.20 in petitioner’s 1999 Federal                
          income tax.  The issue is whether petitioner is entitled to a               
          casualty loss deduction under section 165 in an amount greater              
          than $9,448 allowed by respondent.2  Petitioner resided in                  
          Lorton, Virginia, at time the petition was filed.                           
                                     Background                                       
               The facts may be summarized as follows.  Petitioner is a               
          professor of economics.  In addition, he has published books and            
          articles concerning Africa.  In February, 1999, petitioner’s                
          office at the university at which he taught was destroyed by                
          fire.  Included in the destruction were items of personal                   
          property belonging to petitioner.  On his 1999 Federal income tax           
          return, petitioner claimed a casualty loss deduction for the                
          following:                                                                  
               Books on economics                      $2,000                         
               Books by “famous authors”               1,000                          
               Books on Africa                         5,000                          
               African journals & magazines            3,000                          
               Book manuscript                         15,000                         
               Memorabilia (awards, plaques, etc.)     3,000                          
               Briefcases, fans, etc.                  2,000                          
               Computer printer                        250                            
               Labor/inconvenience/distress            2,000                          

          2  Petitioner concedes that he received other income of $1,000, a           
          distribution from an individual retirement account of $24,792,              
          income from a discharge of indebtedness of $4,696, and interest             
          income of $36.  On his 1999 Schedule A, Itemized Deductions,                
          petitioner claimed a deduction of $21,042.98 for miscellaneous              
          expenses.  Petitioner concedes that $11,737 of those deductions             
          are not allowable.  Respondent concedes that petitioner is                  
          entitled to an additional prepayment credit of $4,958.                      




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