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deduction for a hard disk drive in the amount of $1,500 on their
joint Federal income tax return for the taxable year 1988.
Among the individual casualty losses detailed by petitioners
on Form 4684 attached to their 1991 return were a loss in the
amount of $8,565 for claimed damage to a 1984 Nissan 300ZX
automobile and a loss in the amount of $11,000 for claimed damage
to a 1989 Honda Accord automobile, both caused by the February
flood.
The N.A.D.A. Official Used Car Guide (NADA) lists an average
retail value for various automobile models depending on the
automobile's age and features. NADA also provides a Low Mileage
Table which lists premiums to be added to the average retail
values of low mileage automobiles. NADA lists the average
retail value of a 1984 Nissan 300ZX Coupe Turbo GL as $6,525, and
the low mileage premium to be added to a standard size car with
between 7,501 and 15,000 miles as $2,400, totaling $8,925.
Soon after the flood in April 1991 damaged petitioners'
property, Rod Parker, an insurance adjuster for ABIC, visited
their home to survey the damage and determine the insurance
reimbursement to which they were entitled. He calculated the
full cost to repair the home as $28,425.39 and the replacement
cost of the contents, less depreciation and salvage value, as
$12,187. Based upon Mr. Parker's report, petitioners received
insurance reimbursement from ABIC of $39,059.91, consisting of
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