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BAILEY v. COMMISSIONER

Docket No. 12308-77.

40 T.C.M. 336 (1980)

T.C. Memo. 1980-170

Douglas E. Bailey, Petitioner v. Commissioner.

United States Tax Court.

Filed May 12, 1980.

Attorney(s) appearing for the Case

Robert M. Tyle, 45 Exchange St., Rochester, N.Y., for the petitioner. Anthony M. Bruce, for the respondent.

Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined a deficiency in Federal individual income tax against petitioner for 1975 in the amount of $2,203.65. After settlement of certain matters, there remain for determination the amounts, if any, by which losses from storm damage to petitioner's properties exceeded petitioner's insurance recoveries so as to give rise to deductions under section 165.1

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