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If the loss is a casualty or theft of personal property of the taxpayer, the loss must result from an event that is identifiable, damaging, and sudden, unexpected, and unusual in nature, not gradual and progressive. Examples are hurricanes, tornadoes, and floods. The loss is reduced by a $100 per event and the total loss might be reduced by the ...
A taxpayer’s insured home is destroyed by an accidental fire. Prior to its destruction, the home was valued at its adjusted basis of $100,000 and insured at $130,000. After receiving insurance proceeds, the taxpayer will have a personal casualty gain of $130,000 and a personal casualty loss of $100,000 for a net personal casualty gain of $30,000.
A casualty loss is a type of tax loss that is a sudden, unexpected, or unusual event. [1] Damage or loss resulting from progressive deterioration of property through a steadily operating cause would not be a casualty loss. “Other casualty” are events similar to “fire, storm, or shipwreck.”
Section 1031(a) of the Internal Revenue Code (26 U.S.C. § 1031) states the recognition rules for realized gains (or losses) that arise as a result of an exchange of like-kind property held for productive use in trade or business or for investment. It states that none of the realized gain or loss will be recognized at the time of the exchange.
This is an unpopular result and the Internal Revenue Service (IRS) issued Ruling 98-56 to change the result in the face of public pressure, but only in the case in which the player returned the ball. Under that theory, an individual who catches a record-breaking ball has income at the very moment he possesses it unless he immediately disclaims ...
Section 183(b)(2) provides that a taxpayer may deduct an amount "equal to the amount of the deductions which would be allowable [ . . . ] only if such activity were engaged in for profit, but only to the extent that the gross income derived from such activity for the taxable year exceeds the deductions allowable [ . . .
Under Internal Revenue Code Section 165, "losses of property not connected with a trade or business or a transaction entered into for profit" are not deductible except upon a casualty or theft. [13] In addition, the general rule under Section 183(a) of the Internal Revenue Code does not allow a deduction for an activity that is not engaged in ...
The code provided a way for companies to achieve a safe-harbor valuation. A safe-harbor valuation is one where the IRS must accept the valuation as valid unless the IRS can demonstrate that the valuation is "grossly unreasonable". [12] [13] The code provides three possible ways for companies to achieve a safe-harbor valuation of their common ...