Jane B. Oliver and Robert P. Oliver - Page 9

                                         -  -9                                           
          sent to petitioners covering 1990 and 1991, respondent disallowed           
          the $81,643 casualty loss carryover deduction claimed by                    
          petitioners on their 1990 return, stating that they had not                 
          established that they were entitled to a casualty loss carryover            
          for that year.                                                              
               B.  Flood Damage to Home, Contents, Lawn, and Driveway in              
          1991                                                                        
          During or after 1990, petitioners increased the size of                     
          their home again, adding what they refer to as the "east wing".             
          This brought the total area of their home to 10,000 square feet.            
               In February and April 1991, petitioners experienced flooding           
          at their home.  The February flood caused damage to their home,             
          its contents, their lawn, and their driveway.  The April flood              
          caused damage to their home and its contents.  At the time of               
          both floods, petitioners had flood insurance covering their home            
          and its contents through American Bankers Insurance Co. (ABIC).             
          Petitioners also had flood insurance covering their home and its            
          contents through the National Flood Insurance Program (NFIP).               
          Neither the ABIC flood insurance policy nor the NFIP flood                  
          insurance policy covered the flood damage to petitioners' lawn              
          and driveway.                                                               
               Petitioners had homeowners' insurance coverage provided by             
          Grain Dealers Mutual Insurance Co. and National Farmers Union               
          Standard Insurance Co., but neither of these insurance companies            
          provided insurance coverage for flood damage.  They also had                
          homeowners' insurance coverage provided by Kemper Insurance Co.             



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