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Cohn did not see petitioner’s personal property or
photographs of it. Cohn relied on information from petitioner
consisting of an attachment to her tax return, some handwritten
schedules, and a few receipts.
Petitioner had received some of the personal property that
was damaged by the earthquake as gifts. Her grandmother gave her
some leather-bound books, a magazine rack, and some stemware.
Petitioner did not establish the donor's basis in any of the
gifts. Petitioner inherited some items, including the dining
room chandelier and books, from her aunt.
F. Property Tax Assessment
In January 1990, petitioner applied for a reduction in the
property tax assessment of her home because of the earthquake
damage. San Mateo County reduced the property tax assessment of
her home by $202,200 from $317,000 to $114,800 based on repair
estimates by Cook ($150,000 for foundation repair and $47,600
for other structural repairs) and Arbor Electrical ($4,593 for
electrical repairs) and a telephone conversation with
petitioner’s realtor, Clare Box (Box). Box estimated that the
value of petitioner's home was $389,000 before the earthquake and
$188,057 after the earthquake, for a loss in value of $200,943.
In March 1991, in response to a questionnaire from San Mateo
County, petitioner said that the foundation had been reinforced
to prevent future damage but that the floors had not been
leveled. In March 1993, in response to a questionnaire from San
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