The Section 1231 netting results in an ordinary loss deduction of $9,000, reducing Fred’s taxable income by $9,000.
Step 1 Netting:
Net casualty gain $ 5,000
Step 2 Netting:
Net casualty gain from step 1 $ 5,000
Section 1231 gains 3,000
Section 1231 losses (17,000)
Net section 1231 loss $ (9,000)
The net casualty gain from step 1 is combined with other Section 1231 gains and losses in step 2. This allows the net casualty gain to be offset against other Section 1231 gains and losses. Because there is a net Section 1231 loss for the year, there is no lookback recapture rule to apply.