Stephan Bartsch and Eva Bartsch, a.k.a. Eva Pott Bartsch - Page 11

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          cost in Saigans was not incurred as petitioner’s goods were moved           
          between New York City, petitioner’s former residence, and                   
          Berkeley, petitioner’s new residence.  Therefore, the storage               
          cost incurred by petitioner in Saigans was not incurred in                  
          transit during petitioner’s move from New York City to Berkeley.            
          Accordingly, the Saigans storage cost is not a deductible moving            
          expense for purposes of section 217(a).                                     
               However, petitioner’s AAAAA Storage expense was incurred               
          during the 30-day period after the goods were moved from                    
          petitioner’s former residence, New York City, and before delivery           
          at petitioner’s new residence, Berkeley.  Accordingly, we hold              
          that petitioner is entitled to an additional moving expense                 
          deduction under section 217(a) in the amount of $79 for the in-             
          transit storage expense.                                                    
               E.  Cost of Box Lost in Transit                                        
               Petitioner has failed to substantiate the claimed loss of              
          $2,350 with respect to the box lost in transit from New York City           
          to Berkeley.  Petitioner did not offer any evidence other than              
          his testimony with respect to the cost or value of the contents             
          of the box.  There is no basis in the record for the Court to               
          estimate such an expense under the Cohan rule.  As such, we need            
          not decide whether the value of the box that petitioner claims              
          was lost by the moving company is a deductible moving expense for           
          purposes of section 217.  Accordingly, we hold that petitioner is           






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