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CZIRAKI v. COMMISSIONER

Docket No. 18878-96.

76 T.C.M. 991 (1998)

T.C. Memo. 1998-439

Imre and Gizella Cziraki v. Commissioner.

United States Tax Court.

Filed December 15, 1998.

Attorney(s) appearing for the Case

Jeffrey R. Matsen, Santa Ana, Calif., and Arlin P. Neser, for the petitioners. Ian Russell and Michael H. Salama, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent, by means of a statutory notice of deficiency, determined a deficiency in petitioners' 1992 income tax of $63,874 and a section 6662(a)1 penalty of $12,775. After concessions, the following issues remain for our consideration: (1) Whether petitioners are entitled to a casualty loss deduction in the amount of $220,000 for the 1992 taxable year, and (2) whether any...

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