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RUBEN v. COMMISSIONER

Docket No. 21215-85.

53 T.C.M. 992 (1987)

T.C. Memo. 1987-277

Barney C. Ruben and Estate of Eleanor Ruben, Deceased, Barney C. Ruben and Dante P. Webster, Co-executors v. Commissioner.

United States Tax Court.

Filed June 8, 1987.

Attorney(s) appearing for the Case

Dickinson Thatcher, 14540 Haynes St., Van Nuys, Calif., for the petitioners. Joyce L. Sugawara, for the respondent.

Memorandum Opinion

WRIGHT, Judge:

Respondent determined a deficiency of $135,629 for the taxable year 1981 and additions to tax in the amounts of $6,781 and 50 percent of the statutory interest due on $135,629 under sections 6653(a)(1)1 and 6653(a)(2), respectively.

After concessions, the issues for our consideration are (1) whether the amount of petitioners' deduction for losses sustained in a 1981 fire is limited to...

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