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excessive, (c) the repairs do not care for more than the damage
suffered, and (d) the value of the property after the repairs
does not as a result of the repairs exceed the value of the
property immediately before the casualty.
Petitioners’ claim and the basis upon which they make that
claim fails to meet the criteria set out above entitling them to
a casualty loss deduction. The Court holds that the damage they
sustained did not result from a “closed and completed
transaction”. The damage occurred over a period of time.
Moreover, if petitioners sustained an allowable casualty loss,
petitioners failed to establish the amount of the loss. The
Court, therefore, sustains respondent on this issue.
The second issue is petitioners’ claim to an itemized
deduction for unreimbursed employee expenses in the amount of
$22,138 prior to the 2-percent limitation under section 67(a).
Petitioners included with their return Form 2106-EZ, Unreimbursed
Employee Business Expenses, on which they claimed the following
expenses:
Vehicle expenses $12,213
Parking fees, tolls, etc. 725
Travel expenses away from home 4,250
Business expenses 2,240
Meals and entertainment 2,710
Total $22,138
The amount claimed was disallowed in full in the notice of
deficiency.
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Last modified: May 25, 2011