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Wright v. CIR, 06-60702 (2007)

Court: Court of Appeals for the Fifth Circuit Number: 06-60702 Visitors: 16
Filed: Jul. 05, 2007
Latest Update: Feb. 21, 2020
Summary: United States Court of Appeals Fifth Circuit F I L E D July 5, 2007 IN THE UNITED STATES COURT OF APPEALS Charles R. Fulbruge III FOR THE FIFTH CIRCUIT Clerk _ No. 06-60702 Summary Calendar _ WILLIE A. WRIGHT, Petitioner - Appellant, versus COMMISSIONER OF INTERNAL REVENUE, Respondent - Appellee. _ Appeal from the United States Tax Court Tax Court Docket No. 22905-04 _ Before JOLLY, DENNIS, and CLEMENT, Circuit Judges. PER CURIAM:* Willie W. Wright, pro se, appeals an adverse judgment of the Tax
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                                                                  United States Court of Appeals
                                                                           Fifth Circuit
                                                                        F I L E D
                                                                          July 5, 2007
              IN THE UNITED STATES COURT OF APPEALS
                                                                    Charles R. Fulbruge III
                          FOR THE FIFTH CIRCUIT                             Clerk
                            _____________________

                                 No. 06-60702
                              Summary Calendar
                             _____________________

WILLIE A. WRIGHT,

                                                           Petitioner - Appellant,

                                      versus

COMMISSIONER OF INTERNAL REVENUE,

                                                   Respondent - Appellee.
________________________________________________________________________

                 Appeal from the United States Tax Court
                      Tax Court Docket No. 22905-04
________________________________________________________________________

Before JOLLY, DENNIS, and CLEMENT, Circuit Judges.

PER CURIAM:*

      Willie W. Wright, pro se, appeals an adverse judgment of the Tax

Court. He argues that the Tax Court erred in finding that he was not entitled

to claim a casualty loss deduction. In 1997, Wright’s home was destroyed by

fire. He claimed a casualty loss of $160,402 on his 1997 income tax return for



      *
       Pursuant to 5TH CIR. R. 47.5, the Court has determined that this opinion
should not be published and is not precedent except under the limited
circumstances set forth in 5TH CIR. R. 47.5.4.
the destruction of the home and its contents. The Tax Court found that

Wright failed to carry his burden of substantiating a loss in excess of the

insurance proceeds that he received, as required by 26 U.S.C. § 165(a). That

finding is not clearly erroneous. Wright did not submit evidence of the fair

market value of the property immediately before and immediately after the

fire, nor did he prove his adjusted basis in the property. The judgment of the

Tax Court is, therefore,

                                                                   AFFIRMED.

Source:  CourtListener

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