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it can be ascertained with reasonable certainty that
reimbursement for the loss will (or will not) be received.
As described in our Findings of Fact, petitioners computed
the amount of their loss by subtracting their asserted $265,000
fair market value of the PEDRO immediately after the casualty
from $475,000, petitioners' estimated fair market value of the
PEDRO before the casualty, thereby arriving at a casualty loss of
$210,000, further reduced by the $110,000 insurance recovery paid
to them by USF&G in 1990. We believe some adjustments must be
made to petitioners' computation, the effect of which is to
eliminate any casualty loss deduction for any year.
Petitioners were unable to provide any formal appraisals
that would establish the fair market value of the PEDRO, both
immediately before and immediately after the underwater valve
explosion that caused the loss. However, the record contains
sufficient evidence by which these values can be established.
Petitioner testified that in November, 1988, hoping to make a
quick sale for reasons outlined in our Findings of Fact, he and
his wife decided to lower the asking price to $396,000. We find
this to be the "immediately before" fair market value of the
PEDRO. Petitioner testified that "We had six appointments set
for March and April of 1989 to show the boat, buyers that were
coming in, flying in from out of town. Obviously, in New
England, you don't show boats in January and February until the
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