- 21 - retrofitting the foundation to get the postearthquake loss in value of petitioner's home. Respondent argues that Halpin improperly used a cost-of- repair method. We disagree. Halpin valued petitioner's home by comparing its fair market value before and after the earthquake. An appraiser may consider repair cost estimates in deciding postcasualty fair market value. Pfalzgraf v. Commissioner, 67 T.C. 784, 788 (1977); Abrams v. Commissioner, T.C. Memo. 1981-231. In Abrams, an appraiser used repair estimates to confirm his estimate of postearthquake fair market value, which he based on the market method. In Pfalzgraf, we held that, in estimating the amount of a casualty loss, an appraiser may consider the cost of repairing property to restore it to its precasualty status. 67 T.C. at 788. We rejected the taxpayers’ method of estimating their loss based on the difference between the prefire fair market value and the postfire fair market value because the taxpayers’ method included losses or expenses not caused by the fire. Id. at 789-791. Respondent contends that Abrams and Pfalzgraf do not stand for the proposition that repair estimates may be used to calculate a casualty loss. We disagree. The taxpayer's expert in Abrams concluded that a prospective buyer would discount the value of the damaged building by the cost of needed repairs. He subtracted the estimated cost of repairs from the precasualty fair market value. Similarly, Halpin estimated the loss in valuePage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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