Ahsan Mohiuddin - Page 17

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          the fair market value of the property immediately before the                
          casualty reduced by the fair market value of the property                   
          immediately after the casualty; or (2) the amount of the adjusted           
          basis for determining the loss from the sale or other disposition           
          of the property involved.  A "casualty" is an event due to some             
          sudden, unexpected, or unusual cause, such as a fire, storm, or             
          shipwreck.  Durden v. Commissioner, 3 T.C. 1, 3 (1944).                     
               The only evidence petitioner offered regarding the casualty            
          loss deduction claimed in 1990 was an affidavit of Tex Mayhall,             
          in which Mr. Mayhall states that the damage to petitioner's                 
          automobile occurred due to an absence or an insufficient amount             
          of antifreeze in the automobile.  The affidavit further states              
          that Mr. Mayhall salvaged the automobile for $50 and notified               
          petitioner about the salvage approximately 3 months later when              
          petitioner called to ask about the automobile.  We have long held           
          that in order for an event to constitute a casualty, the event              
          must involve the application of a destructive force which must be           
          the proximate cause of the loss.  See White v. Commissioner, 48             
          T.C. 430 (1967).  Petitioner's loss, if any, did not embody the             
          requisite element of "chance, accident, or contingency", see                
          Powers v. Commissioner, 36 T.C. 1191, 1193 (1961) (quoting                  
          Bachofen von Echt v. Commissioner, 21 B.T.A. 702, 709 (1930)),              
          and is, therefore, no more than a personal expense to petitioner            
          as a result of petitioner's neglect.  Further, even if this were            
          to be considered as a casualty loss, petitioner has offered no              




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