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ESTATE OF BOYLE v. COMMISSIONER

Docket No. 18586-98.

82 T.C.M. 488 (2001)

T.C. Memo. 2001-235

Estate of James W. Boyle, Deceased, Nancy A. Boyle and James H. Case, Co-Personal Representatives and Nancy A. Boyle v. Commissioner.

United States Tax Court.

Filed September 10, 2001.

Attorney(s) appearing for the Case

David W.K. Wong, for the petitioners. Henry E. O'Neill, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

Respondent determined a deficiency of $60,820 in the Federal income tax of petitioner Nancy A. Boyle (Mrs. Boyle) and her deceased husband, James W. Boyle (decedent), for 1995. The only issue1 for decision is whether, under section 165,2 the decedent and Mrs. Boyle properly deducted a casualty loss of $173,833 on their Federal income tax return...

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