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Furthermore, petitioners have not established their adjusted
basis in the property that they allege was stolen. See id. We
sustain respondent’s disallowance of petitioners’ claimed $36,000
theft loss for 2001 and their claimed $1.5 million theft loss for
2002.
C. Moving Expenses
On their 2002 Federal income tax return, petitioners claimed
a $41,952 deduction for moving expenses. Petitioners argue that
they are entitled to the deduction because in 2002 they moved
from Mobile, Alabama, to Florida.
Generally, a taxpayer may deduct moving expenses paid or
incurred during a year in connection with beginning qualifying
work at a new location. Sec. 217(a). Petitioners have failed to
substantiate the claimed moving expenses or to show that the
requirements of section 217(a) have been met.
D. Business Expenses
Respondent disallowed petitioners’ claimed business expenses
for all 3 years: $61,632 in 2001; $1,065,543 in 2002; and
$64,931 in 2003. At trial, petitioner husband contended that $1
million of the claimed business losses in 2002 was due to “bad
7(...continued)
destruction. Petitioners have not, however, identified this
third party and have produced no other evidence of such an offer.
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Last modified: March 27, 2008