Barbara Ann Tudyman - Page 14

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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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