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
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No. 06-60702
Summary Calendar
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WILLIE A. WRIGHT,
Petitioner - Appellant,
versus
COMMISSIONER OF INTERNAL REVENUE,
Respondent - Appellee.
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Appeal from the United States Tax Court
Tax Court Docket No. 22905-04
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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should not be published and is not precedent except under the limited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.