- 2 -
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.
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011