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fires, storms, and shipwrecks. Popa v. Commissioner, 73 T.C.
130, 132-133 (1979); White v. Commissioner, 48 T.C. 430, 434-435
(1967); Durden v. Commissioner, 3 T.C. 1, 3-4 (1944). As we put
it in Billman v. Commissioner, 73 T.C. 139, 141-142 (1979)--
We cannot believe that the Internal Revenue Code
was designed to take care of all losses that the
economic world may bestow on its inhabitants. It is
restricted in its description of a casualty loss to
“losses aris[ing] from fire, storm, shipwreck, or other
casualty, or from theft.” Certainly these taxpayers
did not suffer from “fire, storm, [or] shipwreck.” Of
course they suffered. But, was it from “other
casualty?” To us, “other casualty” means a similar
kind of occurrence to “fire, storm, [or] shipwreck.”
* * *
Firstly, Poppe’s successful foreclosure proceeding is not
the type of event that is sudden, undesigned, violent or
forceful, unexpected, and accidental. Secondly, even assuming
that petitioners lost all value of the Island and R.K. on account
of the Army Corps of Engineers’ action of denying permits to
develop the Island, that denial is not the type of event that is
sudden, undesigned, violent or forceful, unexpected, and
accidental. Thus, Laney’s loss was not from an “other casualty”.
Powers v. Commissioner, 36 T.C. at 1193; see Beltran v. United
States, 441 F.2d 954, 960 (7th Cir. 1971); Alvarez v. United
States, 431 F.2d 1261, 1264 (5th Cir. 1970).
We hold, for respondent, that Laney’s claimed 1983 loss did
not arise from fire, storm, shipwreck, or other casualty.
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