Suzanne Z. Ataky - Page 6




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          or appraisal of its preaccident and postaccident fair market                
          value, we are unable to calculate or even to estimate the amount            
          of a casualty loss deduction allowable to petitioner.  A repair             
          estimate that was produced by petitioner did not indicate the               
          expertise of the individual making the estimate, is addressed to            
          an individual other than petitioner, lists a license plate number           
          for the car different from the license plate number listed in the           
          police accident report, and is dated 6 months after the accident.           
               We disallow as unsubstantiated petitioner’s 2003 claimed               
          $3,050 casualty loss deduction relating to a 2002 car theft and a           
          2003 car accident.                                                          
               Petitioner now argues that the $2,060 claimed bad debt                 
          deduction relates to airline tickets that she purchased in 2003             
          for a contractor as compensation for the contractor’s future                
          services.  Petitioner argues that the contractor did not perform            
          the services, that the contractor refused to refund to petitioner           
          the cost of the airline tickets, and that as a result petitioner            
          in 2003 realized a $2,060 bad debt.                                         
               Because petitioner, among other things, did not produce                
          credible evidence that she purchased airline tickets for a                  
          contractor, petitioner has failed to substantiate the claimed bad           
          debt deduction.                                                             
               We disallow as unsubstantiated petitioner’s $2,060 claimed             
          bad debt deduction.                                                         







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