David Daniel and Annette Daniel - Page 12

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                  We find that petitioners have substantially complied with                              
            the substantiation requirements and have made a good faith                                   
            attempt to provide respondent with sufficient information.  We                               
            accept Mrs. Daniel's estimates of the fair market values of the                              
            donated items.  Accordingly, we hold that petitioners are                                    
            entitled to charitable contribution deductions for their                                     
            donations to the Veterans in the amounts claimed on their 1991                               
            and 1992 returns.                                                                            
                  The second issue for decision is whether petitioners are                               
            entitled to a casualty loss deduction for 1992. Petitioners                                  
            claimed a casualty loss in the amount of $11,300 on their 1992                               
            return for the following items:                                                              
                  Flood Damage to Wall To Wall Carpet & Dry Wall                $5,940                   
                  Water Damage to Wall Cabinets                                 1,610                    
                  Wind Storm Damage - Loss of Five Trees & Removal  3,750                                
                  After accounting for certain limitations, petitioners                                  
            claimed a casualty loss deduction in the amount of $3,100.                                   
            Respondent disallowed the claimed deduction in the statutory                                 
            notice of deficiency.                                                                        
                  Section 165(a) allows as a deduction any loss sustained                                
            during the taxable year and not compensated for by insurance or                              
            otherwise.  In the case of an individual's nonbusiness property,                             
            the deduction is limited to losses that "arise from fire, storm,                             
            shipwreck, or other casualty, or from theft."  Sec. 165(c)(3).                               
                  The parties agree that petitioners sustained a casualty loss                           
            within the meaning of section 165(c)(3) during 1992.  Respondent,                            




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