Following a quarrel with his wife, Biltmore Blackman (plaintiff) set some of her clothing on fire on the kitchen stove. Blackman asserted that he completely extinguished the fire and then left the house. However, the fire spread and destroyed their home. Blackman was charged with arson, but was never tried. Blackman filed an insurance claim for the loss of his home, which was denied. Blackman then claimed the loss as a casualty-loss deduction on his federal tax return. The federal tax commissioner (commissioner) (defendant) denied the casualty-loss deduction and imposed an accuracy-related penalty on Blackman for understating his tax liability. Blackman petitioned the United States Tax Court for a redetermination.