Judith E. Stephenson Fast - Page 12

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          are applicable.  See sec. 1.170A-13(a)(1), Income Tax Regs.                 
          Under that regulation, the taxpayer need only have a receipt from           
          the donee containing the name and address of the donee, the date            
          and place of the contribution, and a description of the property.           
          Sec. 1.170A-13(b)(1), Income Tax Regs.  We find that petitioner             
          has satisfied the requirements of section l.170A-13(a)(1), Income           
          Tax Regs., with respect to the remaining items and is entitled to           
          a $600 charitable contribution deduction.                                   
          Casualty Loss                                                               
               Petitioner claims a casualty loss deduction in the amount of           
          $710.38.  Respondent argues that the loss in question was not a             
          casualty but instead deterioration, and that petitioner has in              
          any event presented no evidence of the amount of the loss.                  
          Petitioner experienced flooding in one room of her house that was           
          lower than the rest of the structure.  Such flooding had not                
          occurred prior to 1993, but in that year it happened several                
          times during a 1- to 2-month period.  Section 165(c)(3) allows a            
          deduction for losses arising from “fire, storm, shipwreck, or               
          other casualty”.  A casualty is a sudden, unexpected loss, not              
          steady deterioration over time.  Durden v. Commissioner, 3 T.C. 1           
          (1944).  We need not decide whether petitioner’s loss was a                 
          casualty, because we find that she has not proved the amount of             
          the loss.  The measure of the deduction is the difference in the            
          fair market value of the house before and after the loss, not to            





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