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ROWLEY v. COMMISSIONER

Docket No. 9480-77.

38 T.C.M. 1297 (1979)

T.C. Memo. 1979-338

Worth and Jane P. Rowley v. Commissioner.

United States Tax Court.

Filed August 27, 1979.

Attorney(s) appearing for the Case

Daniel F. Shea, 4610 Mission St., San Francisco, Calif., for the petitioners. Carolyn M. Parr, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

By letter dated June 15, 1977 respondent determined a deficiency in income taxes paid by petitioners Worth and Jane P. Rowley for their taxable year ended December 31, 1975 in the amount of $4,509.48. The sole issue for our decision herein is whether petitioners incurred an "other casualty" within the meaning of section 165(c)(3), I.R.C. 1954, when their wooden sailing vessel was damaged by "dry rot...

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