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adequately proven entitlement to this deduction. The only
documentation he provided for this loss was a list of property
allegedly destroyed along with dollar amounts representing the
value petitioner assigned to each item. This list neither
substantiates the loss of the personal property, nor establishes
petitioner’s tax basis in the property. We therefore hold that
petitioner may not deduct any amount for the loss of personal
property in the Bronx Boulevard house fire.
Since we have held that petitioner is not entitled to the
deductions claimed for mortgage interest, real property taxes, or
casualty losses, and since petitioner stipulated that he received
the unreported interest income, we uphold respondent’s
determination in the notice of deficiency.
Decision will be entered
for respondent.
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Last modified: November 10, 2007