- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011