CHAMALES v. COMMISSIONER

Docket No. 14839-98.

79 T.C.M. 1428 (2000)

T.C. Memo. 2000-33

Gerald Chamales and Kathleen Chamales v. Commissioner.

United States Tax Court.

Filed February 3, 2000.


Attorney(s) appearing for the Case

Bruce I. Hochman, Dennis L. Perez, and Stuart A. Simon, for the petitioners. Michele F. Leichtman and Jason M. Silver, for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

NIMS, Judge:

Respondent determined a Federal income tax deficiency for petitioners' 1994 taxable year in the amount of $291,931. Respondent also determined an accuracy-related penalty of $58,386 for 1994, pursuant to section 6662(a).

The issues for decision are as follows:

(1) Whether petitioners are entitled to deduct a net casualty loss of $751,427 for the taxable year 1994; and

(2) whether...

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